The 1938 Giro di Lombardia was the 34th edition of the Giro di Lombardia cycle race and was held on 23 October 1938, over a course of . The race started and finished in Milan. The race was won by the Italian Cino Cinelli, who reached the finish line at an average speed of , preceding his countrymen Gino Bartali and Osvaldo Bailo.
101 cyclists departed from Milan and 60 completed the race.