Pretty much yes, though I was angling toward coordination difficulties between
people creating complexity which is “accidental” from the perspective of the whole system but “essential” to individual actors given their incentives and what they can rely on, either for purely social-maneuvering reasons or for other reasons as well. And more specifically, how this happens even when the accidental complexity isn't really in line with the group's values or with the values of the individual actors. The way that this grounds out in a technical sense is scenarios like the one you describe, so I think we're talking about the same broad set of phenomena.
Further, there's different levels and causes of “coordination didn't happen”, such as “we tried, but got confused and didn't have time to understand each other properly” or “actively sabotaging everyone else's ability to deal with the aggregate system so that I can get ahead”… and somewhere in there is one that stands out to me as specifically interacting with technical complexity, along the lines of “I want my piece to not have to be the one that changes and/or takes on other costs”. Which is part of the social dynamic of moving externally-essential complexity around within the aggregate system and potentially creating ripples of accidental complexity along the way.
(Whether and how this also happens when the information systems in question are human minds rather than software components might be relevant but also an exercise for the reader…)