The 1938-39 season was Newport County's 18th season in the Football League Third Division South and they had been ever-present except for the 1931-32 season since the introduction of the Third Division North & South in 1920.
The 1938-39 season was Newport County's 17th season in the Football League Third Division South and 18th overall in the Football League. They had been ever-present in the third tier except for the 1931-32 season since the introduction of the Football League Third Division in 1920.