Oral healthcare is attracting much attention after decades of neglect from policymakers. Recent studies have shown a strong association between oral and overall health, which can lead to serious health problems. Availability of oral healthcare services is an essential part of ensuring universal healthcare coverage. More importantly, current gaps in its accessibility by minority or marginalized population groups are crucial public health as well as ethical concerns. One notable effort to address this issue comes from Non-Governmental Organizations (NGOs), which offer (...) oral healthcare services for non-insured refugees. However, the challenge remains that these care services are not comprehensive, which has implications for the refugees’ oral and general health. In this article, we discuss this complex issue in the German healthcare context by including ethical reflections. Therefore, the purpose of this article is to discuss the ethical challenges related to oral healthcare services provided by NGOs for refugees in Germany. First, we will introduce the general oral healthcare context worldwide and in Germany. Second, we will provide a general description of the oral healthcare services provided by NGOs for refugees in Germany, as well as an overview of existing gaps. This will provide us with the context for our third and most important task—discussing the ethical implications of the gaps. In doing so, and since the ethical implications can be several, we demarcate the scope of our analysis by focusing on the specific ethical issues of justice, harm, and autonomy. Finally, we offer some recommendations for how to move forward. (shrink)