While the Form 5500 itself does not require you to upload a copy of the SPD, having a current, compliant Summary Plan Description is a key part of ERISA compliance—and it is expected if you’re filing Form 5500 for a health or welfare benefit plan.
Why it matters:
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Form 5500 asks for plan information that should match what’s in the SPD, such as the plan sponsor, plan year, and plan number.
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If the Department of Labor audits the plan, they will almost always ask for a copy of the SPD or Wrap SPD.
Filing Form 5500 without a corresponding SPD or Wrap document can raise compliance red flags and create potential penalties—even if the filing itself was technically accurate.
If multiple benefits are filed under a single Form 5500, a consolidated Wrap SPD should clearly describe how those benefits are bundled under one ERISA plan.