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Governed MCP Server

Governed MCP Server

A reference implementation of the layers an enterprise has to add around a Model Context Protocol (MCP) server before it can carry production traffic: identity, tool-level authorization, connector isolation, audit, and observability.

The protocol part of MCP is the easy part. What decides whether an MCP layer can be handed over to an internal platform team is everything wrapped around it — who may call which tool, against which system, with what recorded afterwards. This repository builds that out in tranches, on top of a stateless 2026-07-28 server.

Status: tranches 1, 3 and 6 implemented — identity and authorization, the ServiceNow domain with its lighthouse use case, and the operational documentation in docs/. 55 tests, in-memory and over real HTTP. Tranches 2, 4 and 5 under Roadmap are designed but not yet implemented, and are marked as such.

Nothing here has been deployed against a live Azure tenant, and the ServiceNow connector runs against an in-process mock by default — so the repository has no credentials in it and needs none to run.

Why stateless first

No initialize handshake, no Mcp-Session-Id. Every request carries its own protocol version and capabilities, so any replica can answer any request — this goes behind a plain round-robin load balancer with zero sticky-session configuration, which was the main operational pain point with MCP servers before this spec.

That is not only an operational convenience. It removes session affinity as a constraint on how the layer is deployed, which is what makes the rest of the roadmap tractable: authorization, rate limiting and audit are all simpler to reason about when there is no per-session server state to keep consistent across instances.

Related MCP server: MCP Gateway Demo

Target architecture

flowchart LR
    C[MCP clients] --> APIM[API Management<br/>token validation, rate limit]
    APIM --> S[MCP server replicas<br/>stateless]
    S --> AZ[Entra ID<br/>tokens + role claims]
    S --> P[Policy engine<br/>tool RBAC, classification]
    S --> K[Key Vault<br/>connector secrets]
    S --> CN[Connector layer]
    CN --> SN[ServiceNow]
    CN --> TR[Transport systems]
    S --> O[Audit log + OpenTelemetry<br/>Azure Monitor]

Real today: the stateless server replicas, their transport, token verification against the identity provider, and the policy engine. Key Vault, the connector layer, API Management and the Azure Monitor export are target state.

Setup

python3 -m venv venv
source venv/bin/activate        # venv\Scripts\activate on Windows
pip install -r requirements.txt

pip install -r requirements-dev.txt   # to run the tests
python -m pytest -q

Files

  • server.py — the MCP server. Two tools (get_shipment_status, list_delayed_shipments) and one resource template (shipment://{id}), built with MCPServer (the v2 rename of FastMCP — same decorator API you'd already recognize). create_server(auth_mode=...) selects the authorization posture.

  • policy.yaml — who may call what, and what needs a human. The whole access-control model, as a reviewable document.

  • governance/ — the layers wrapped around the server:

    • verifier.py — Entra ID token validation, implementing the SDK's TokenVerifier protocol

    • policy.py — the policy document and the decisions it yields

    • middleware.py — enforcement, applied uniformly to every request

    • approval.py — the human-in-the-loop gate

    • request_state.py — the signing key ring shared across replicas

    • audit.py — the authorization decision trail

    • servicenow.py — the ITSM connector, live or mocked

    • devidp.py — a local identity provider, so all of the above is testable with no Azure tenant

  • client.py — exercises the server along two independent axes, transport and protocol era:

    • python client.py — in-memory, no transport at all (fastest way to test)

    • python client.py --http — talks to a running server.py over Streamable HTTP, same as a real client would

    • add --legacy to either one to negotiate as a pre-2026 client (see "Old clients" below)

The tools are backed by an in-memory fixture, not a real system. They are shaped like the transport and logistics domain deliberately, so the authorization and connector layers have something realistic to wrap — but they are placeholders, and tranche 2 replaces them.

Run it

Terminal 1:

python server.py
# Uvicorn running on http://127.0.0.1:8000/mcp

Terminal 2:

python client.py --http

Expected output:

tools: ['get_shipment_status', 'list_delayed_shipments']
get_shipment_status(SHP-1002) -> {'id': 'SHP-1002', 'status': 'delayed', ...}
list_delayed_shipments(24) -> [{'id': 'SHP-1002', ...}, {'id': 'SHP-1004', ...}]
shipment detail -> SHP-1004: Zeebrugge -> Koln, status delayed, ...
protocol version negotiated: 2026-07-28

Authorization

Three postures, selected with --auth:

Mode

Tokens

Use

off (default)

none required

the transport demo above

dev

in-process identity provider

development and the test suite

entra

a real Entra tenant

configured via environment variables

dev and entra differ only in where signing keys are fetched from — a static JWKS versus the tenant's JWKS endpoint. The verifier, the policy and the enforcement path are identical, so the tests exercise the code that runs in production, and moving to a tenant is configuration rather than a rewrite.

Try it

python server.py --auth dev --port 8000 &

# Mint tokens. The signing key is persisted to .devidp-key.pem so a second
# process signs with the key the running server verifies against.
READER=$(python server.py --auth dev --print-token tlo.reader)
NOROLE=$(python server.py --auth dev --print-token)

No token — a challenge pointing at the metadata document, per RFC 9728:

$ curl -i -X POST localhost:8000/mcp -d '{"jsonrpc":"2.0","id":1,"method":"tools/list"}'
HTTP/1.1 401 Unauthorized
www-authenticate: Bearer error="invalid_token", error_description="Authentication
  required", resource_metadata="http://127.0.0.1:8000/.well-known/oauth-protected-resource/mcp"

With $READER, the call succeeds. With $NOROLE the token is valid — it just carries no role that grants the tool:

tools visible: []                       # discovery is filtered to the caller
MCPError -32003 Access denied for 'get_shipment_status': caller holds none of
                the roles this tool requires

What is actually enforced

Token validation (governance/verifier.py). Signature against the issuer's published keys, then three checks that decide whether this is a real gate or decoration:

  • Audience, exactly. The token must name this server. This is the confused-deputy defence: a token a user legitimately holds for another service must not be replayable here, and a token this server receives must not be forwardable upstream. It is the most commonly skipped check in MCP deployments, and the reason token passthrough is called out as an anti-pattern in the specification.

  • Asymmetric algorithms only. Permitting an HMAC algorithm lets a caller sign their own tokens using the public key as the shared secret — the algorithm-confusion attack. alg: none is rejected for the same reason. The constructor refuses an unsafe algorithm rather than trusting the caller to pass a safe list.

  • Expiry, issuer, and required claims, with a small clock-skew allowance.

Per-tool access control (policy.yaml, governance/policy.py). Entra app roles arrive in the token's roles claim and are matched against a declarative document — data, not code, so it can be reviewed by people who do not read Python, diffed in a change request, and pointed at during an audit. Two properties are deliberate:

  • Fail closed. A tool with no policy entry is denied. Shipping a tool without an authorization decision makes it unreachable, which is a visible bug, rather than public, which is a silent one.

  • Fail fast. Every role a rule references must be declared. A typo in a role name stops the server from starting, instead of producing a rule that can never match — and a rule that never matches is invisible in testing and looks exactly like a working deny.

Enforcement (governance/middleware.py) is server middleware, so it sees every request before dispatch and applies to every tool uniformly. There is no per-tool decorator for an author to forget. Denials are raised before the handler runs, so an unauthorized call never reaches a downstream system. tools/list is filtered to what the caller may actually invoke — listing a tool someone cannot call leaks the shape of systems they have no access to, and invites an agent to plan around a call that will always be refused.

Two tiers, one decision point. Scopes gate whether a caller may reach the server at all, at the transport layer. Roles gate which tools they may then invoke, in the policy. Authorization decisions live in exactly one place, which is what makes "why was this allowed" answerable.

Audit (governance/audit.py) records every decision as a JSON line — principal, target, outcome, reason, classification, roles required and held. It is deliberately a separate stream from application logging, with its own handler and no propagation to the root logger: they have different readers, retention and access rules, and the SDK's rich handler wraps long lines, which silently corrupts anything meant to be parsed later.

{"timestamp":"2026-07-31T19:58:22Z","principal":"user@example.com","method":"tools/call",
 "target":"get_shipment_status","outcome":"deny","reason":"caller holds none of the roles
 this tool requires","classification":"internal","required_roles":["tlo.operator",
 "tlo.reader"],"granted_roles":[],"argument_names":["shipment_id"]}

Argument values are not recorded. Shipment identifiers are low risk, but the same path will carry incident bodies and customer references once the connectors land, and a log that quietly became confidential-tier is worse than one that never held the data.

Shadow mode. --shadow audits decisions without enforcing them, so a policy can be trialled against real traffic and the calls it would break found before it starts breaking them.

The lighthouse use case

Transport and Logistics Operations, split into a read half and a write half because they warrant different privileges:

Tool

Roles

Classification

Human approval

assess_shipment_delay

reader, operator, admin

internal

no

search_incidents, get_configuration_item

reader, operator, admin

internal

no

raise_shipment_incident

operator, admin

confidential

yes

assess_shipment_delay correlates a late shipment to the configuration item that handles it and to any incident already open against that item, then recommends an action. It changes nothing. That separation matters in an agent loop: an assessment that quietly opened tickets would mean an agent could not look without also touching production.

The whole flow, over HTTP, against the mock ServiceNow:

1. reader assess       -> Raise a new incident against CI-TMS-02.
2. reader raise        -> DENIED: caller holds none of the roles this tool requires
3. operator, declined  -> BLOCKED: not approved: a human declined the action
4. operator, approved  -> INC0020001  CI-TMS-02
5. re-assess           -> Enrich INC0020001 rather than opening a duplicate.

The approval gate

raise_shipment_incident contains no approval code. The policy marks it requires_approval and the middleware holds the call, so the gate cannot be forgotten by a tool author — the same argument as for authorization.

Mechanically it is the 2026-07-28 input-needed/resume flow, which replaced the elicitation callback: the server returns an InputRequiredResult carrying the question, the client puts it to a human, and the call is retried with the answer and an opaque request_state attached.

The state is client-controlled on the way back in, so a gate that trusts it is decorative — approve a low-urgency incident, retry the same state with urgency: 1. The first version of this repository hand-rolled an HMAC-signed state binding tool, principal, arguments and expiry to close that hole. It was then deleted, because the SDK's RequestStateBoundary already does it, and does it better: AES-256-GCM with a key-rotation ring, binding the method, the tool, a digest of the arguments, a salted principal hash, an audience and an expiry, fail-closed in both directions. Shipping hand-written cryptography beside a reviewed implementation, for no additional property, is not a trade worth making. governance/approval.py is now thin, and the tests assert against the real control rather than a local re-implementation of it.

What is still trusted is the client, which relays the human's decision. Nothing in the protocol lets a server verify a human was really asked. The gate raises the bar from "an agent can act unilaterally" to "the client must lie about consent" — a real improvement, and not the same as proof. A control needing the stronger property belongs in ServiceNow's own approval workflow.

ServiceNow

Two backends behind one interface. mock is the default: an in-process store answering the same calls with the same shapes, so the repository and its tests run with no instance and no credentials. live addresses a real instance over the Table API, with credentials read from SERVICENOW_INSTANCE, SERVICENOW_USER and SERVICENOW_PASSWORD — a Personal Developer Instance is enough to exercise it.

python server.py --auth dev --servicenow live

The mock is not only a convenience. A connector that runs in-process is one whose failure modes can be tested — an expired credential, a configuration item that does not resolve — and those are exactly the paths that never get exercised against a live instance, because provoking them there is awkward.

Incident records are projected onto a narrow model rather than passed through. A ServiceNow incident carries well over a hundred columns, many of them free text; forwarding all of it to a language model is how data reaches somewhere it was never classified for.

Running more than one replica

The approval flow spans two round trips, so the state sealing it must be verifiable by whichever replica answers the retry. The SDK defaults to a process-local key, which would quietly reintroduce the session affinity this whole design exists to avoid. Give every replica the same key:

export MCP_REQUEST_STATE_KEYS=$(python server.py --print-state-key)

It is a rotation ring — the first key seals, every key unseals — so rotation is three deployments with no dropped approvals. See the runbook. Unset, the server still runs and warns that it is single-replica only.

Against a real tenant

export MCP_ENTRA_TENANT_ID=<tenant-guid>
export MCP_RESOURCE_AUDIENCE=api://governed-mcp-server   # the app registration's ID URI
python server.py --auth entra

Roles come from app roles defined on that app registration and assigned to users or service principals. Signing keys are fetched from the tenant's JWKS endpoint and cached by key id, so key rollover needs no restart. This path is implemented but has not been run against a live tenant.

Old clients

The claim that one endpoint serves both eras is worth verifying rather than taking on faith, so --legacy makes the client negotiate the way a pre-2026 client does:

python client.py --http --legacy
# ...
# protocol version negotiated: 2025-11-25

Same server, same URL, no server-side flag — only the client's negotiation policy changed. What's actually different:

  • Default (mode="auto") — the client probes server/discover at 2026-07-28. Anything that isn't positive evidence of a modern server (a JSON-RPC error, an HTTP 4xx, an unparseable result, or a discover result advertising only handshake-era versions) falls back to initialize. The fallback is a denylist, so an unknown legacy server degrades rather than failing.

  • --legacy (mode="legacy") — skips the probe entirely and sends initialize, byte-identical to pre-2026 behavior. In-memory this also drives the real stream loop instead of the direct per-request path, so it exercises the old code path rather than just relabeling the version.

The negotiated version picks how every later request is stamped: 2026-07-28 puts protocol version, client info and capabilities into each request's _meta, which is what makes any replica able to answer it. 2025-11-25 sends only the Mcp-Protocol-Version header, because the rest lives in the session that initialize set up.

One limitation: you can't pin an arbitrary old version. mode= takes "auto", "legacy", or a modern version string — passing "2025-11-25" raises ValueError and tells you to use mode="legacy". The handshake-era version is the server's pick (newest both sides know, so 2025-11-25 here). Simulating a genuinely older client (2025-06-18, 2024-11-05) means dropping to ClientSession and building the InitializeRequest yourself — the server honors it, the Client wrapper won't emit it.

A platform rarely controls all of its clients, so single-endpoint backwards compatibility is a requirement rather than a nicety — and it is one fewer migration to coordinate during onboarding.

Proving statelessness to yourself

Run server.py on two ports, then alternate requests between them and confirm every one succeeds regardless of which instance answers:

python server.py --port 8000 &
python server.py --port 8001 &

for p in 8000 8001 8000 8001; do
  python client.py --http --url http://127.0.0.1:$p/mcp | tail -1
done

There's no shared session store to wire up, which is the whole point of the release. Put a real load balancer in front instead of the loop and nothing about the server changes.

Note: MCPServer("name", port=...) is no longer valid in v2 — port configuration moved onto uvicorn.run(..., port=...), which is what the --port flag above drives.

Roadmap

Ordered by how much each tranche says about running MCP in an enterprise, rather than by implementation order.

  1. Identity and authorization. Done — see Authorization. Protected-resource metadata, WWW-Authenticate challenge, JWKS validation through a custom TokenVerifier, strict audience validation, and declarative per-tool RBAC with an audit record per decision. Still outstanding here: the SDK exposes identity_assertion_enabled (SEP-990 ID-JAG, the RFC 7523 jwt-bearer grant) for enterprise identity provider flows, which is the right primitive for on-behalf-of chains and is not yet wired up.

  2. Connector architecture. A connector base with declarative manifests — authentication mode, Key Vault secret reference, rate limit, retry and circuit breaker, data classification — with tools generated from manifests rather than hand-decorated. Record/replay mock mode so the repository runs with no credentials.

  3. ServiceNow domain and a lighthouse use case. Done — see The lighthouse use case. Table API connector, the delay-to-incident flow, and a declarative human approval gate on the 2026-07-28 input-needed/resume pattern. Still outstanding here: incident state transitions and work-note enrichment, and a run against a live Personal Developer Instance.

  4. Audit and observability. OpenTelemetry tracing is on by default in this SDK and no-op until an exporter is attached; attach one. Spans carrying principal, tool, connector, classification, policy decision, latency and cost — plus a separate append-only audit log, redacted by classification. Audit and telemetry are different deliverables with different retention and access rules, and collapsing them into one stream is a mistake. Dashboards and alert rules committed as artefacts.

  5. Deployment. Bicep for Container Apps, API Management, Entra app registrations, Key Vault, Log Analytics and private endpoints. The API Management policy — token validation, per-subject rate limiting, logging — matters more here than the compute configuration.

  6. Operational documentation. Done — see docs/. A security baseline with classification tiers, a STRIDE threat model and the MCP-specific threats outside it; runbooks for key rotation and revoking access; four architecture decision records; and a guide to onboarding the next domain.

License

Apache License 2.0 — see LICENSE and NOTICE. Apache rather than MIT for the explicit patent grant, since this is meant to be readable and reusable inside an enterprise.

Notes on the SDK

mcp[cli]==2.0.0rc1 is pinned exactly — the v2 line isn't stable yet, so pin exact versions and expect to bump this. Anything depending on mcp in production should add an upper bound like mcp>=1.27,<2 so the eventual stable v2 doesn't surprise you.

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