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The map shows all known former hotel APODs used across Australia, between December 2002 and December 2022. These are presented alongside the current four Immigration Detention Centres (IDCs) and three Immigration Transit Accommodation (ITAs).

By clicking on each pin on the map, a location of the hotel APOD is shown, along with any known data (eg date of use/closure, number of people detained) and a street-view image of the hotel from Google maps. Links are also provided identifying the original source document from where the data was drawn.

The locations shown on the map provide an indication of the range of hotel APOD sites used across Australia over the last 20 years, while recognising that many more sites remain unknown. 

The Department of 91���˰涶�� Affairs has typically refused FOI requests to establish the full scope of the APOD network, or have provided heavily redacted materials. In April 2022, the Department  that it does not possess a list of places approved for use as APODs. 

The data presented in the map is drawn from recent Senate Estimates questions, as well as evidence tendered by the government in  challenging the legality of the use of hotels as APODs. It also draws on reports published by the Commonwealth Ombudsman (in its oversight role for places of detention under control of the Commonwealth) and the Australian Human Rights Commission (AHRC), the two independent inspectorates with access to APODs. Each entry on the map includes a link to the source material used to identify the location as a hotel APOD.

An APOD is a place of immigration detention approved in writing by the Minister for Immigration or his/her delegate. 

APODs were introduced on 2 December 2002 as an alternative option to closed detention facilities. The concept was introduced in a Migration Series Instruction issued by the Department of Immigration (MSI 371). As noted in the MSI, the term APOD is not used or defined in the Migration Act 1958 (Cth). Rather the government purports to approve APODs as places of immigration by relying on the definition of ‘immigration detention’ in s 5(1)(b)(v) of the Act, which includes places approved by the Minister in writing. It should be noted that the validity of relying on the definition section of the Act in this manner to create a power to authorise detention in APODs is the subject of a .

The stated purpose of the policy when it was introduced was to facilitate the accommodation of ‘unlawful non-citizen' women and children and other persons with special needs in alternative places of detention. The focus was thus very much on the specific needs of detainees that could not be met in traditional closed detention facilities.

However,  as the Commonwealth Ombudsman and Australian Human Rights Commissioner have :��

“a practice has also emerged for hotels to be used as APODs to house people where this does not stem from a specific need of the person being held, but for other reasons, such as relieving overcrowding in other immigration detention facilities.” 

This shift in the purpose and scale of hotel-based detention was exemplified by the use of hotels to detain the so-called , many of which were single men, brought to Australia from the offshore processing facilities in Nauru and Manus Island for health treatment between 2019 and 2022. 

Throughout the COVID-19 pandemic, there were  raised about the suitability of hotels to provide sufficient care for detainees, many with complex health care needs.  were held by detainees as well as by refugee rights organisations and local community advocates, drawing attention to sites such as the Park Hotel and Mantra Bell Preston Hotel in Melbourne, as well as the former Kangaroo Point Central Hotel in Brisbane. The  of Novak Djokovic at the Park Hotel in Melbourne alongside the Medevac transferees in January 2022 again shone the spotlight on the practice. 

While it is welcome that many refugees and asylum seekers have been since been from hotel detention into the community on bridging visas, other , including those who have had their visas cancelled or refused on character grounds.

In March 2021, the Australian Border Force  to Senator Nick McKim in Senate Estimates that from 1 January 2018 to 31 January 2021, there were 170 APODs used in Australia. The table below breaks down these numbers for each state and territory.

The Australian Border Force also confirmed that as of 31 January 2021, 56 hotels were designated as APODs.

A recent  by the Ombudsman and the AHRC stated that as of 31 July 2022 there were 77 hotels designated as APODs under the Migration Act, with 7 in operation at the time.

In each case, the locations of each APOD site were either not provided or were redacted. From these two accounts, it can be determined that more than 20 additional hotel APOD sites were designated for use from January 2021 to July 2022 alone. 

The locations shown on the map provide an indication of the scope of hotel APOD sites used across Australia over the last 20 years, while recognising that the location of many more sites remain unknown. 

In terms of the number of people held in APODs, the monthly detention statistics released by the Department of 91���˰涶�� Affairs only provide the number of persons within APODs by state and territory, not by location or facility, and do not distinguish between types of APODs (ie hospitals, aged care homes, or hotels). As of 31 July 2022, the Department of 91���˰涶�� Affairs provided the  of the number of people being held in APODs:

Earlier statistics provided in Senate Estimates by the Australian Border Force provide some insights into the proportion of people held in hotels as compared to other APODs. As of 31 December 2021, 102 detainees were held in APODs, with less than 87 of these in hotel accommodation. 

These figures represent a significant reduction in the number of people held APODs in recent years. For example, as of , there were 2,486 people detained in APODs on the Australian mainland (including 1,126 children), and an additional 2,213 men, women and children held at APODs on Christmas Island and Cocos and Keeling Island.

The Commonwealth Ombudsman and Australian Human Rights Commissioner  that as of 31 July 2022, the average length of time for current individuals in detention in hotels was 69 days, with the longest continuous period of time an individual has been detained in hotel APOD being 634 days.

The location of current hotels used as APODs, as well as the profile and background of the people currently being detained in at those sites is unknown. However, as noted above it appears the number of asylum seekers and refugees held in hotels has decreased significantly in recent times, in part due to the release of the Medevac transferees on bridging visas. Yet, other migrants, refugees and asylum seekers continue to be held in hotel APODs, many for extended periods of time.

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• Hedrick, K.,Armstrong, G.,Coffey, G.,Borschmann, R. (2020) '' BMC Public Health, 20, 1 - 10
• Essex, R., Kalocsányiová, E., Young, P., & Mccrone, P. (2022) '' Journal of Immigrant and Minority Health, 24(4), 868-874.