Current physics commonly qualifies the Earth system as ‘complex’ because it includes numerous different processes operating over a large range of spatial scales, often modelled as exhibiting non-linear chaotic response dynamics and power scaling laws. This characterization is based on the fundamental assumption that the Earth’s complexity could, in principle, be modeled by (surrogated by) a numerical algorithm if enough computing power were granted. Yet, similar numerical algorithms also surrogate different systems having the same processes and dynamics, such as Mars or Jupiter, although being qualitatively different from the Earth system. Here, I argue that understanding the Earth as a complex system requires a consideration of the Gaia hypothesis: the Earth is a complex system because it instantiates life—and therefore an autopoietic, metabolic-repair (M,R) organization—at a planetary scale. This implies that the Earth’s complexity has formal equivalence to a self-referential system that inherently is non-algorithmic and, therefore, cannot be surrogated and simulated in a Turing machine. I discuss the consequences of this, with reference to in-silico climate models, tipping points, planetary boundaries, and planetary feedback loops as units of adaptive evolution and selection.