That’s an interesting idea. I’m not sure how well hell maps to Banks’ books in terms of choice though.

In most religious depictions, one of hell’s predominant characteristics is its inescapability—either logistically or by the mental limits of its inhabitants. Tons of Banks’ work, on the other hand, has a through line of “people could choose to leave the Culture, they’re fundamentally in their situation by (extremely unconstrained!) choice”. This comes up in the idea of Subliming, being Stored, many characters’ choices to commit suicide/decline immortality, or just plain leaving the Culture as many do.

Plenty of his characters are in hells of their own making/choosing, or are tortured by other people, which I think is definitely a commentary on the sources of suffering being behavioral rather than just environmental, but I’m not sure it follows that “therefore the Culture is hell”.