Assessment is made on the vulnerability of the tunnels to the earthquake loads based on the holistic risk analysis approach. In the paper, a risk assessment model is firstly established by using the analytical hierarchy process as a screening tool and then process is made by means of probability statistics method so as to obtain the comprehensive weight values of the vulnerability of the tunnels to the earthquake loads and achieve the risk assessment diagram of the tunnels. A preliminary verification of the proposed model is conducted by comparing the prediction results with the data collected in the earthquake cases. The study indicates that it is completely feasible to use the holistic risk analysis approach to assess the complex and variable issue of the vulnerability of the tunnels.