Research is foundational to address health burdens posed by pandemics. Pandemics are also radically non-ideal research environments characterised by urgency, complex whole-of-society impacts, overburdened health systems and uncertain, rapidly-evolving, evidentiary landscapes. This presentation explores real-world cases from front-line researchers and research regulators around the globe during COVID-19. These cases demonstrate the complexity of ethical considerations that were engaged with, often beyond the scope of guidance in national and international research ethics standards. Core challenges during the pandemic included complex interactions between national policy-makers researchers, and reviewers with differing obligations, values and priorities; navigating research prioritisation and de-prioritisation priorities and processes; responding to evolving boundaries between research, surveillance and monitored emergency use; and adapting and conducting adaptive research. Questions also arose about the extent to which pandemic contexts give rise to salient ethical considerations which should influence research design, quality and dissemination; ethical review processes and priorities; health and research data curation and sharing; and approaches to protecting research participants and addressing inclusion and vulnerability. Grounded in real-world experiences in the COVID-19 pandemic, this presentation reflects on the challenges arising when seeking to embed ethics in the prioritisation, design, review, conduct and dissemination of pandemic research. It proposes priorities for the development of conceptual frameworks and guidance that are responsive to the breadth of responsibilities and complexities associated with decision-making in pandemic research, and approaches to building capacities to recognise, critically evaluate and appropriately respond to salient ethical considerations in such contexts.