Transport Safety Minister Harry Duynhoven says people may not be using bicycles because they do not like wearing safety helmets.
Mr Duynhoven made the comments at a transport forum in Wellington on Wednesday, while talking about reducing carbon emissions by getting people out of their cars.
Mr Duynhoven is not suggesting the use of helmets should be scrapped, saying they should still be compulsory, because of the safety benefits.
But he wonders how many people would be cycling in New Zealand if they did not have to wear them.
A national group that works with government and local authorities to build a safe cycling environment says the compulsory wearing of helmets is a vexed issue.
The Cycling Advocates Network says New Zealand is the only country that forces cyclists to wear helmets and it is time to review the effectiveness of the legislation.