Teleodynamic Closure and the Definition of Intelligence.

It has been proposed that intelligence is "an emergent property of consciousness… the ability to intentionally solve challenges and adapt to new situations and to an ever-changing environment," anchored in the far-from-equilibrium (FFE) thermodynamics of intelligent systems (Vitas, Cvjetović and Dobovišek, BioSystems 263, 105776, 2026; hereafter VCD). We argue that this proposal, while moving in a productive direction, omits the specific dynamical regime that distinguishes intelligent organisation from mere dissipative complexity: the teleodynamic regime, in which a system's constraints participate in their own generation through recursive, constraint-on-constraint dynamics - teleodynamic closure - and thereby produce end-directedness from non-intentional substrates. Without that layer, the central operative terms of the definition - "intentionally," "adapt," "challenge" - remain undischarged. We identify five lacunae: (i) the FFE invocation is thermodynamic but not yet teleodynamic; (ii) intentionality is presupposed rather than emergentist-derived; (iii) the proposed cognition→consciousness→intelligence ordering is misaligned with the aneural-cognition literature; (iv) "adaptation" without a constraint-generation account is operationally indistinguishable from passive equilibration; (v) the definition lacks any treatment of constraint plasticity. We propose a reconstructed definition: intelligence is the capacity of a teleodynamically organised system to generate, propagate and modify the informational-regulatory constraints of its cognitive subsystem such that the system's own end-directedness is preserved and extended across novel adaptive challenges in a far-from-equilibrium environment. Building on the regulatory tradition (Bich et al., 2016; Bich and Moreno, 2016), we distinguish life (closure of constitutive constraints), cognition (the informational-regulatory subsystem controlling those constraints), and intelligence (the constraint-plastic mode of that subsystem). The reconstruction is grounded in a timescale-separated dynamical sketch and worked biological cases (chemotaxis and metabolic switching in E. coli). It is substrate-independent yet thermodynamically anchored, consistent with aneural cognition, independent of any prior commitment to consciousness, and operationalisable for artificial intelligence, astrobiology and biological cognition research.