3 | Key observations and concerns Figure 2: Average length of time for people held in immigration detention facilities in Australia (January 2018 – January 2023) 900 750 600 450 300 436 416 428 446 500 483 503 494 502 496 520 478 496 545 553 557 581 604 629 641 700 668 685 689 683 687 736 761 781 773 806 150 31-Jan-23 30-Nov-22 30-Sep-22 31-Jul-22 31-May-22 31-Mar-22 31-Jan-22 30-Nov-21 30-Sep-21 31-Jul-21 31-May-21 31-Mar-21 31-Jan-21 30-Nov-20 30-Sep-20 31-Jul-20 31-May-20 31-Mar-20 31-Jan-20 30-Nov-19 30-Sep-19 31-Jul-19 31-May-19 31-Mar-19 31-Jan-19 30-Nov-18 30-Sep-18 31-Jul-18 31-May-18 31-Mar-18 31-Jan-18 0 Number of days Figure 2: Data taken from Department of Home Affairs, Immigration Detention and Community Statistics Summaries <https://www. homeaffairs.gov.au/research-and-statistics/statistics/visa-statistics/live/immigration-detention>. The average length of time spent in immigration detention is far higher in Australia than in comparable jurisdictions. For example, in the United Kingdom in 2021, 76% of all detainees had been in immigration detention for fewer than 7 days. In Canada, the average length of detention was 24.1 days between July and September 2021.36 While the average length of time spent in immigration detention continues to increase, the average length of time spent in detention within hotel APODs specifically has reduced significantly in recent times. For example, the average length of time that individuals had spent detained in hotel APODs was 322 days as at 31 August 2020, but had reduced to 69 days by 31 July 2022.37 This reflects a shift in the nature of the individuals being detained, from being predominantly members of the Medevac cohort to now being primarily individuals 18 whose visas have been cancelled on character grounds under s 501 of the Migration Act. While it is positive that the average time spent in hotel APODs is being reduced, this does not diminish the significant concerns about the excessive lengths of time that individuals are being detained, both in closed immigration detention generally and in hotel APODs specifically. The observations made by the Commission in previous inspection reports with respect to the negative impacts of prolonged detention continue to be relevant: Prolonged detention is a risk factor for mental ill-health, as the negative impacts of immigration detention on mental health tend to worsen as the length of detention increases.38 This is of particular concern in the current context given