The 1938 Denver Pioneers football team was an American football team that represented the University of Denver as a member of the Mountain States Conference (MSC) during the 1938 college football season. In its third season under head coach Bill Saunders, the team compiled an overall record of 4–4–1 record with a mark of 3–2–1 against conference opponents, tied for second place in the MSC, and was outscored by a total of 86 to 65.