This research aims to develop risk breakdown structure specifically for virtual learning projects in higher institution. Transition from physical face-to-face study into virtual learning practices during COVID-19 mitigation phase had been selected as main focus to construct risks identification. Opinions and experiences from 35 stakeholders in university level had been gathered and analyzed using triangulation and meta-language of risk statement methods, in order to maintain statements’ validity and quality based on project management’s standard. All registered risks were listed using universal risk breakdown structure format, which emphasized on three risk areas: internal, external, and technology, in order to categorize risk based on its sources and identify area with high exposure of risk. The result proposed 11 risk statements with highest exposure of risk on technology area. This result indicated that virtual learning organizers need to consider strategies and mitigation process in technology area, specifically on the infrastructure readiness, user capabilities, and communication gap inside the virtual environment.