220 billion lines of COBOL.
5 governance tools.
Zero re-platforms.
Banks. Insurers. Government departments. Defence contractors. Healthcare. Real-time payments. They all sit on COBOL mainframes. None can move off in time for DORA Article 17, EU AI Act Article 12 audit, or NIS2 Article 23. MEOK COBOL Substrate bridges the existing estate to modern AI governance with 5 MCP-native tools — no re-platform required.
Why the bridge, not another rewrite
COBOL modernization fails 40-70% of the time. Banks have spent decades migrating off, and the COBOL keeps running. The mainframe team retires; the system stays.
What changed in 2024-2026 isn't the mainframe — it's the governance perimeter. EU AI Act Article 12 wants audit logs across every decision-making system, AI or not. DORA Article 17 requires a Register of Information for all third-party ICT. NIS2 Article 23 wants 24-hour incident reporting on essential entities. None of that requires moving the COBOL — just signing what it does.
That's what COBOL Substrate is. Five MCP-native tools running outside the mainframe, reading copybooks + CICS + JCL, generating signed evidence packs that auditors verify by URL. The mainframe doesn't change. The compliance posture does.
5 integrated tools
Copybook Parser
Parse COBOL copybooks → JSON schemas with PII detection
→ GDPR + PCI-DSS + HIPAA + SOX field map
CICS Bridge Assessment
Evaluate CICS programs for MCP integration readiness
→ RACF/ACF2/TopSecret security gap report
JCL Batch Scanner
Analyze JCL job streams for data lineage + governance
→ Dataset compliance flags + scheduling audit
COBOL-Coder-14B Transpiler
FPT-Software COBOL-Coder model, compiler-validated
→ Python/Java with business-logic preservation
Governance Crosswalk
Map COBOL estate to DORA + NIS2 + EU AI Act articles
→ Signed compliance evidence pack
By industry
Tier-1 core systems still on COBOL; DORA Article 17 third-party register required
Regs: DORA, Basel III, MiFID II, AML 6AMLD
Policy admin + claims on mainframes; FIDA + IDD overhauls
Regs: FIDA, IDD, Solvency II, EU AI Act
IRS, SSA, NHS, HMRC + EU equivalents — billions of lines, no migration plan
Regs: GDPR, ATRS (UK), OMB M-24-10 (US)
MoD payroll, MOD supply chain, US DoD ERP all COBOL
Regs: ITAR, NIST 800-171, UK MOD JSP
HL7 over COBOL backbones; EHR refresh cycles missed
Regs: HIPAA, EU AI Act MedDevice, MDR
SEPA Instant + FedNow + UK FPS migrating off mainframe
Regs: PSD3, FAIR Banking, PCI-DSS v4
FPT COBOL-Coder-14B → 73.95% compile success vs GPT-4o's 41.8%
Generic LLMs hallucinate COBOL constructs they've never seen at training time. The FPT-Software COBOL-Coder-14B model is fine-tuned on real COBOL estates and gives us 73.95% compiler-validated translation success vs GPT-4o's 41.8%. That's the difference between a transpilation that works and one that needs a human rewriter at every function boundary.
We integrate the model behind a compliance-aware wrapper: every translation generates a signed attestation chained into the existing MEOK audit-logger evidence pack, so modernization itself becomes auditor-defensible work — not just the output code.
Pricing
- ✓ uvx cobol-bridge-mcp
- ✓ Local attestations
- ✗ COBOL-Coder-14B
- ✗ Signed evidence
- ✓ All 5 tools
- ✓ COBOL-Coder-14B
- ✓ Signed evidence chain
- ✓ DORA/NIS2/AI Act crosswalk
- ✓ 99.9% SLA
- ✓ Substrate Pro features
- ✓ On-premise deployment
- ✓ DORA Art 17 register
- ✓ Dedicated CSM
- ✓ White-label reseller
- ✓ PO / invoice billing
How to evaluate in 14 days
- Days 1-3: Drop us 3-5 anonymised COBOL copybooks. Substrate runs Copybook Parser + PII detection + GDPR/PCI/HIPAA/SOX mapping.
- Days 4-7: Point us at one CICS region + JCL job stream. We run CICS Bridge Assessment + JCL Batch Scanner — surface security + lineage gaps.
- Days 8-11: Pick the top-3 risk programs from steps 1-2. COBOL-Coder-14B transpiles them to Python with compiler-validated output. Side-by-side diff for your team.
- Days 12-14: Governance Crosswalk emits a signed evidence pack ready for your next DORA / NIS2 / EU AI Act audit. We hand off to your team or escalate to Defence tier.
Regulatory clocks (DORA Art 17, AI Act Art 12, NIS2 Art 23) + COBOL ecosystem updates. One email a month.
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MEOK AI Labs · CSOAI LTD · UK Companies House 16939677 · MIT source · COBOL-Coder-14B by FPT-Software (used per its licence) · hello@meok.ai