Arbitration limits discovery, which is a principal reason parties choose it and a principal complaint once a dispute arises.
Provider rules typically provide for exchange of documents on which the parties rely, and for reasonable requests for documents relevant and material to the outcome. Broad requests modelled on court practice are refused.
Depositions are not provided as of right in most commercial rules, and tribunals allow them sparingly — commonly none, or one or two per side in larger matters.
Third parties. Arbitrators may issue subpoenas for testimony and documents at a hearing. Whether they may compel pre-hearing document production from a non-party divides the circuits, and the workaround is to convene a preliminary hearing at which the documents are produced.
Electronic discovery. Rules and guidance direct tribunals to limit it, and to require the requesting party to justify the burden.
Agreeing more. Parties may provide for expanded discovery in the arbitration clause or by agreement at the outset, which is worth considering where the facts sit with one side.
Practical guidance. Front-load the document requests, make them specific and justified by relevance to a defined issue, and raise disputes at the preliminary conference rather than months later.