The Ministry for Children has lawyers that work with vulnerable children across the country, often in the youth and family courts.
Oranga Tamariki spokesperson Caz Anderson said the vacancies in Gisborne and Southland were currently being covered by other regions.
"Where vacancies occur, we assess the level of work and what resources are required before deciding the appropriate course of action. In some cases, work is redistributed across the workforce. For example, the Dunedin office is supporting Southland; similarly the Napier office is supporting Gisborne.
"Like many public service agencies, Oranga Tamariki has a temporary hiring freeze in place whilst we work through a formal organisational change proposal with kaimahi," Anderson said.
The government department has proposed cutting 447 jobs, reducing its workforce by 9 percent.
That would involve 632 roles being disestablished - including 70 vacant roles- with 185 new roles created.
Public Service Association (PSA) assistant secretary Fleur Fitzsimons said not having lawyers located in Southland and Gisborne was "letting down children and families" in those communities.
"Locally based lawyers develop critical relationships and they understand their local communities."
She said the lawyers also supported social workers to make lawful and appropriate decisions about the care and protection of children.
Fitzsimons said they were concerned that lawyers covering from other regions would be "forcing more work onto people who are already overworked."
"This isn't a sensible step on any level," she said.
Job cuts were also likely to impact the legal team.
The Law Society said it had been advised Oranga Tamariki was consulting on a proposal that would impact their lawyers across the country.
It said while it had no information about the detail of this proposal, it remained "concerned at the prospect of reduced legal services in this critical area".
Law Society family law section chair Lauren Pegg said they held "significant concerns for the impact of these proposed changes on vulnerable children and young people, as well as the proper functioning of the Family Court".
"The services these lawyers provide cannot simply be carried out by others in the organisation, for example social workers, who already face complex and heavy workloads," she said.
Pegg said affected lawyers and their colleagues would also be stressed by the cuts and that presented an "ongoing risk to their wellbeing, and the wellbeing of those who may be left to deal with the aftermath of such decisions".
