It is well known that acoustic emission (AE) signals, generated by external impacts or damages such as crack initiation, mainly propagate in the form of Lamb waves in plate-like structures. In this work, MEMS-based resonant capacitive micro-machined ultrasonic transducers (CMUTs), which are designed for sensing out-of-plane displacements, have been verified by finite element method (FEM) modeling and theoretical analysis for their feasibility of detecting low-order Lamb waves (A0 and S0). First, combining the propagation theory of Lamb waves and the “spring-mass-damper” model of CMUTs, the out-of-plane sensing mechanism has been explained, together with the analytical expression of sensitivity. Then, simulations based on FEM have been carried out to show that the designed CMUTs are sensitive to out-of-plane displacements, while extremely insensitive to in-plane displacements. Meanwhile, a transient analysis has found the potential abilities of CMUTs for sensing A0 and S0 lamb waves. Besides, the sensing characteristics of CMUTs have also been investigated, including the influence of squeezed-film damping, the amplitude of the input signal, the cell number, and cell space. Finally, the ball drop impact is simulated to show the potential of identifying the location of the AE source by CMUTs. Our studies reveal the out-of-plane sensing behaviors of CMUTs for Lamb waves and may have the potential in promoting the miniaturization and integration of AE sensors.