This descriptive qualitative research aimed to find out the implementation of HOTS (Higher Order Thinking Skill)-based probability learning in SMK Muhammadiyah Bobotsari. The subjects were the eleventh-grade teacher and students of Accounting 1. The data were collected using observation, interviews, and documentation, then analyzed using data reduction, data display, and conclusion, and the validity was tested using technique triangulation. The results showed that the probability learning taught by the teacher was not planned quite well yet. It could be seen from the basic competencies, indicators, and learning media that had not supported this HOTS-based learning. The teacher also did not implement HOTS-based learning which could be seen from the learning model, method, and stages that did not conform to the lesson plan. However, the learning model, method, and stages themselves had conformed to HOTS-based learning. The assessment was also not based on HOTS. The questions gave obvious information that the students needed and they also used the problems that had been used in learning probability before. Moreover, they also only used the form of essay questions.