The COVID-19 pandemic has dramatically impacted tourism and leisure activities worldwide, especially in the hospitality sector. This paper has a conceptual and empirical motivation based on two objectives. First, it identifies several of the primary factors behind the vulnerability of tourism to COVID-19 (tourism dependency, market structure, the supply of rural accommodation, and health incidence of the pandemic). Second, it constructs a vulnerability index to COVID-19 using Spain and its 50 provinces as case. The main results obtained indicate that tourism to the Balearic Islands, the Canary Islands, the provinces of the Mediterranean coast, and Madrid, in which the state capital is located, present higher vulnerability to COVID-19, yet with different underlying factors. Our methodology and results are of interest to policymakers in terms of the short- and medium-term strategic policies that can be employed to mitigate current and future shocks.