With more than 40 million confirmed cases of COVID-19 globally, the pandemic is continuing to severely challenge health systems around the world. Countries with high numbers of refugees face an additional burden on COVID-19 preventive and curative services made available and accessible to refugees. Turkey hosts the largest number of refugees globally, with a total of 4 million in 2020. Over 98% of refugees in Turkey reside in urban areas in large, crowded cities such as Istanbul, Gaziantep, and Hatay posing severe challenges for all health responses, including COVID-19. This study provides insights and analysis on the current situation for refugees, migrants under temporary protection and undocumented migrants in Turkey by focusing on the right to health and access to health care under pandemic conditions. Its main aim is to discuss the challenges and opportunities for COVID-19 responses relating to refugees, migrants under temporary protection and undocumented migrants in Turkey.