A Crown media funder is preparing for legal action from Māori radio stations not funded by the Government.
Te Māngai Pāho has told ministers that there are a number of significant iwi groups that still do not have a pūtea.
The funder said it had requests to finance another four broadcasters. The Crown currently funds 21 stations.
It warned the Government that if it could not provide funding, it was conceivable one or more of the iwi aligned to the stations could use the judicial process to secure money.
The word of caution was contained in a Briefing to Incoming Ministers.
Te Māngai Pāho's briefing notes show its last application to the government for more resources to add additional stations to the radio network was not successful.
No cash for all - Te Reo radio
Reo FM is one of the stations which does not receive Crown money. The Ōtaki-based broadcaster was set up in 2007 with a $380,000 establishment grant from Te Rūnanga o Raukawa.
Airing programmes exclusively in Te Reo Māori, the station was forced to live off that money for the first five years of its operation.
Daphne Luke, the chair of the Raukawa Media Charitable Trust - which was the licence holder for Reo FM - said many rangatahi got involved and there was great support from kaumātua.
But she said: "From 2010/2011 the funding started to run out, and the second-hand equipment we bought in 2007 came back to bite us. We had technical issues at the station and up at our tower on Forest Hill."
Ms Luke said since 2011 Reo FM has struggled to stay on air, and they considered closing down last year.
"Fortunately Te Wānanga o Raukawa said it was of such importance to the institute that it was prepared to support the station for another twelve months, to get us back on our feet".
Ms Luke said the programming was now largely automated, playing mostly music, and they had made many approaches to Te Māngai Pāho for funding.
"The standard response that we've always received verbally is that the agency's hands are tied, funding is capped at 21 stations and there's no room for Reo FM.
"One of the things we worked out last year was that the iwi, between the start up and the on-going costs, has put in almost one million dollars, and we've not had one cent from Te Māngai Pāho."
Ms Luke said she got a similar response from politicians.
"We have a right to funding - just like every other iwi. Under the Treaty of Waitangi, it promised protection of our taonga, and Te Reo is a taonga. Taking action through the Waitangi Tribunal is something we're considering".
Te Māngai Pāho said in the year ahead, it had been asked to carry out a feasibility study on options for expanding the network.
"While the outcome of the study will not be known until later this financial year, it is possible that recommendations could include returning to government for further funding for these additional stations."