Ghana has a relatively liberal abortion law dating back to 1960 under the Criminal Code of 1960, Act 29, sections 58-59 and 67; amended in 1985 to expand the carder of abortion providers and access to services amidst emerging ethical concerns that impede abortion access. ÌýWe used an interest and principle-based concept analysis to examine and discuss key ethical dilemmas confronting access to Comprehensive Abortion Care (CAC) during the peak of the COVID-19 pandemic in Ghana. Following ourÌýarguments that ethical dilemmas were confrontingÌýaccessing and providing CAC services during the peak of the COVID-19 pandemic in Ghana, weÌýobserved that, despite the relatively liberal nature of the Ghanaian abortion law, abortion seekers and providers continue to experience ethical conundrums alike as they try to maneuver between the abortion law, personal values, and genuine concerns for CAC either on-demand, medical or legal grounds during the COVID-19 pandemic.ÌýWe also observed various legal and ethical ambiguities in implementing the abortion law, compelling both abortion seekers and providers to coin multiple interpretations of the law to make CAC ethically justifiable under all circumstances during the pandemic. In line with the best international standards on CAC, there is a need to expand the CAC guidelines of Ghana to cater for future pandemics.ÌýThis requires legal interpretations of the abortion law and public education on the policy and legal provisions for CAC in Ghana to enhance informed decision-making for CAC in future pandemics when required.