This paper advances a developmental foundation for sequencing content in critical evaluation in visual arts education. This foundation is based on differences in representational autonomy mapped between children in the primary school years and early adolescence. The notion of representational autonomy in the visual arts is characterised as the varying degree to which, in the evaluation of art works children between these ages are able to conceptualise as transparent, an opaque referential relation between pictures and the subject matter they depict. In conjunction with PernerÕs theory of meta-representation (where ‘opacity’ is conceived as the faculty of a person to re-register understanding within the constraints of an alternative representational perspective, or theory of mind) children’s responses to questions, based on six opaque referential relations amongst entities entailed in the critical evaluation of art, revealed a conceptual re-organisation whereby an understanding of the causal role of an artist’s agency was integrated into pictorial reasoning, somewhere around the middle of the primary school years. However, even by the end of those years, an understanding of the beholder’s (picture spectator’s) mind remained largely unintegrated into children's reasoning.