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High positivity rate of COVID-19 in Indonesia leads to the creation of government policies to limit human mobility. One of the sectors most affected by these policies is the tourism sector. In 2019, tourism sector contributed approximately US$ 15 billion. However, income from this sector has fallen by up to 90% due to the sharp decrease of tourist arrivals during the pandemic. One of the tourism sectors that has experienced a significant impact due to COVID-19 is community based tourism especially water-based tourism. This study examines adaptation policies taken by the community-based tourism sector, namely Umbul Ponggok and Tawangmangu in response to the pandemic. In this research, we adopt the IPCC definition of climate adaptation. IPCC defines adaptation as special acts, systematic change, as well as institutional reform induced by the volatility of climate. We are particularly interested in how community-based tourism sector restructures and reorganizes its operation and how they mobilises local community to support its adaptation policies. We conclude that, similar to Tompkins and Adger (2004) account on adaptation policy, adaptive capacity can vary between regions and even households. Therefore, adaptation policies require strategies and management approaches that are flexible and inclusive and consider the varied characters of communities and individuals.