Ombudsman, Hamlison Bulu, said 196 had submitted their returns but 445 public sector leaders had not.
He said if they did not submit their annual returns by 14 March their names would appear in the official gazette and then later in court.
Bulu said leaders would also be hit with a $US20,000 penalty if they didn't submit their returns on time with a further $185 added each day.
The Ombudsman appealed to all officials to respect the leadership code.
Leaders in provinces could submit their annual returns to the provincial headquarters.
The President of Vanuatu, Tallis Obed Moses, was included in the list of leaders still to file their returns.
This is the first year all annual returns must be submitted to the Office of the Ombudsman, after the law was changed last year.
Previously, since 1998 all annual returns had been submitted to the Clerk of Parliament.