Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2) is a highly transmissible and pathogenic coronavirus that emerged in late 2019 in Wuhan, China. The SARS-CoV-2 has caused a pandemic of acute respiratory disease named ‘coronavirus disease of 2019’ - COVID-19 - which has threatened human health and public safety. COVID-19 was first reported in Kenya on the 12th March 2020. Since March till November 2020, the rate of COVID-19 infection is high in Kenya, with over 60,000 cases being reported in all 47 counties in Kenya resulting in over 1000 deaths and approximately 40,000 recoveries. This study looked at structural risk factors to COVID-19 that existed before the outbreak and may have direct and indirect effects on COVID-19 risk across all the 47 counties in Kenya. These factors are COVID-19 exposure and vulnerability and lack of adaptive capacity to COVID-19. The Index for Risk Management (INFORM) COVID-19 risk index was used as a composite index to combine the various risk factors through assigning weights. From the COVID-19 risk index counties such as Nairobi, Kiambu, Meru, Kakamega and Nakuru have been identified to be at high risk from health and humanitarian impacts of COVID-19 that could potentially overwhelm national response capacity. These counties are characterized by high COVID-19 cumulative confirmed cases, high number of vulnerable populations such as the elderly, disabled and population of street persons/ outdoor sleepers. These counties also have low numbers of ICU (Intensive Care Unit) and COVID-19 isolation centres. Therefore, the KRCS and other humanitarian organizations are recommended to prioritize COVID-19 preparedness and response efforts in these counties with high COVID-19 risk score. Such efforts would include conducting mass campaigns through public address systems, distribution of personal protective equipment (PPEs) to vulnerable communities, community sensitization and advocacy for prepositioning of adequate ICU and isolation centres. The INFORM COVID-19 risk index composite index approach employed in this study could be downscaled at subcounty to ward level to better understand COVID-19 risk at community level. The approach used in this study could be replicated to other countries to better help humanitarian organization in prioritizing their COVID-19 preparedness and response efforts in counties with high COVID-19 risk score.