Should deposits at central banks be reported as central bank eligible assets?

Should sight- or term-deposits at central banks, reported in AE-ASS 010 Loans on Demand or AE-ASS 100 Loans and advances other than loans on demand, be reported in columns 030 or 080 as central bank eligible assets? The collateral framework of ECB does not foresee that deposits at a central bank can be pledged as collateral for operations with the Eurosystem. However, deposits might be blocked by a central bank to collateralize intra-day overdrafts related to settlement.

Annex XVII chapter 2.1.2 states that r020 “loans on demand” includes the balances receivable on demand at central banks and other institutions. Concerning r100, it includes loans and advances, that is, debt instruments held by the reporting institutions that are not securities, other than balances receivable on demand.
In this case, sight- or term-deposit at central banks, if they are available on demand, have to be reported in r020.

Annex XVII chapter 2.1.3 defines central bank eligibility as “assets held by the reporting institution which are eligible for operations with those central banks to which the reporting institution has access”. Thus, sight or term deposits at central banks should be treated as central bank eligible only if they are accepted as collateral by the central bank.