The aim of this paper is twofold: (1) to assess whether the construct of neural representations plays an explanatory role under the variational free-energy principle and its corollary process theory, active inference; and (2) if so, to assess which philosophical stance - in relation to the ontological and epistemological status of representations - is most appropriate. We focus on non-realist (deflationary and fictionalist-instrumentalist) approaches. We consider a deflationary account of mental representation, according to which the explanatorily relevant contents of neural (...) representations are mathematical, rather than cognitive, and a fictionalist or instrumentalist account, according to which representations are scientifically useful fictions that serve explanatory (and other) aims. After reviewing the free-energy principle and active inference, we argue that the model of adaptive phenotypes under the free-energy principle can be used to furnish a formal semantics, enabling us to assign semantic content to specific phenotypic states (the internal states of a Markovian system that exists far from equilibrium). We propose a modified fictionalist account: an organism-centered fictionalism or instrumentalism. We argue that, under the free-energy principle, pursuing even a deflationary account of the content of neural representations licenses the appeal to the kind of semantic content involved in the aboutness or intentionality of cognitive systems; our position is thus coherent with, but rests on distinct assumptions from, the realist position. We argue that the free-energy principle thereby explains the aboutness or intentionality in living systems and hence their capacity to parse their sensory stream using an ontology or set of semantic factors. (shrink)