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The aim of this paper is twofold: (1) to assess whether the construct ofneural representations plays an explanatory role under the variationalfree-energy principle and its corollary process theory, active inference; and(2) if so, to assess which philosophical stance - in relation to theontological and epistemological status of representations - is mostappropriate. We focus on non-realist (deflationary andfictionalist-instrumentalist) approaches. We consider a deflationary account ofmental representation, according to which the explanatorily relevant contentsof neural representations are mathematical, rather than cognitive, and afictionalist or instrumentalist account, according to which representations arescientifically useful fictions that serve explanatory (and other) aims. Afterreviewing the free-energy principle and active inference, we argue that themodel of adaptive phenotypes under the free-energy principle can be used tofurnish a formal semantics, enabling us to assign semantic content to specificphenotypic states (the internal states of a Markovian system that exists farfrom equilibrium). We propose a modified fictionalist account: anorganism-centered fictionalism or instrumentalism. We argue that, under thefree-energy principle, pursuing even a deflationary account of the content ofneural representations licenses the appeal to the kind of semantic contentinvolved in the aboutness or intentionality of cognitive systems; our positionis thus coherent with, but rests on distinct assumptions from, the realistposition. We argue that the free-energy principle thereby explains theaboutness or intentionality in living systems and hence their capacity to parsetheir sensory stream using an ontology or set of semantic factors.

Is the free-energy principle a formal theory of semantics? From variational density dynamics to neural and phenotypic representations