A weak version of the life-mind continuity thesis entails that every living system also has a basic mind (with a non-representational form of intentionality). The strong version entails that the same concepts that are sufficient to explain basic minds (with non-representational states) are also central to understanding non-basic minds (with representational states). We argue that recent work on the free energy principle supports the following claims with respect to the life-mind continuity thesis: (i) there is a strong continuity between life and mind; (ii) all living systems can be described as if they had representational states; (iii) the ’as-if representationality’ entailed by the free energy principle is central to understanding both basic forms of intentionality and intentionality in non-basic minds. In addition to this, we argue that the free energy principle also renders realism about computation and representation compatible with a strong life-mind continuity thesis (although the free energy principle does not entail computational and representational realism). In particular, we show how representationality proper can be grounded in ’as-if representationality’.