From Legacy Documentation to OSCAL: An MCP-Based Agent Pipeline for Threat-Informed Continuous Compliance in Critical Infrastructure

Abstract: In critical infrastructure, operational technology environments often cannot be actively scanned, and yet active system feedback is needed for risk assessment and compliance. This paper presents a non-invasive, MCP-grounded multi-agent pipeline that converts natural-language system descriptions into source-verified knowledge graph and audit-ready artifacts in the NIST OSCAL format for continuous automated compliance management. The architecture decouples LLM-based reasoning from deterministic knowledge retrieval against authoritative threat-intelligence sources, reducing the risk of fabricated vulnerabilities and hallucinated attack paths. In an evidence-based synthetic scenario of a water utility, the pipeline achieves 0.90 CVE recall and perfect D3FEND recall. It generates a schema-valid OSCAL System Security Plan and an OSCAL Security Assessment Report. Nevertheless, the core insight is not that grounding via MCP eliminates errors (e.g., hallucinations) entirely from the pipeline, but that it shifts errors into the first phase of asset extraction from the natural language description. Here, a single incorrectly extracted entity can lead to genuine but irrelevant CVEs in subsequent stages of the pipeline, which consumes time and resources. However, it makes the remaining risk visible, verifiable, and suitable for a time-efficient manual review, since the infrastructure (e.g., version numbers, OS, etc.) is typically known.