In this paper, we analyse the conditions and constraints which might favour, or on the contrary hinder, a large-scale implementation of inquiry-based mathematics and science education (IBMSE), on the basis of our work within the PRIMAS project in 12 European countries. As a complement to the approach through the analysis of teachers' beliefs and practices (see Engeln et al. 2013), we tackle this issue from a systemic institutional perspective. Indeed, in our approach, we consider teachers as actors of institutions, representing some disciplines, embedded in a school system, sharing some common pedagogical issues, in relation to society. Our sources of information are easily accessible public documents. With a theoretical background from Chevallard's anthropological theory of didactics (ATD), we organized our analysis according to four levels of institutional organization that co-determine both content and didactical aspects in the teaching of mathematics and sciences: society, school, pedagogy and disciplinary. Our approach is systemic in the sense that we do not focus on teachers as individuals, nor on the curricula, the organization of teachers' training or the textbooks themselves. Rather, we trace the way the conditions and constraints are operative, provide the main results of our analysis and draw out a few perspectives according to our four levels of didactical determination. Finally, in the conclusion, we reflect on the limits and potential of our analysis.