We discuss the sensitivity of the JUNO neutrino detector to the Migdal ionization signal triggered by nuclear scattering events produced by sub-GeV weakly interacting massive particles (WIMPs). Exploiting JUNO’’s large target mass and the annual modulation effect we find that the aggregate rate from many independent and indistinguishable WIMP events in JUNO’s liquid scintillator can be isolated from the total dark rate of the photomultipliers, potentially providing for spin-dependent interactions a world-leading sensitivity across the sub-GeV mass range.