The 25-year-old from Sydney carded 2-under par 71 on the demanding, narrow tree-lined fairways.
Kemp started on the back nine and got off to a relatively slow start when she dropped a shot at the par-five 15th, but picked up four birdies and another bogey on the front nine.
"I'm very happy. It's a tough course; you've really got to place the ball and there are a lot of three-woods, five-woods off the tee," Kemp said.
Italian Stefania Croce leads at 3-under par, with Kemp and Spaniard Tania Elosegui sharing second position.
"I trusted my game," said Croce, who turned professional in 1989.
"I think course management and being positive on every hole was the key."
Karen Lunn is the next best Australian, tied 27th at 2-over par in a group including England's defending champion Melissa Reid.
Nikki Garrett and Rebecca Flood are a further shot back and tied 44th.