This part on page https://docs.unity3d.com/Manual/tvOS.html still has a note about needing to use ODR for apps over 200mb. Apple increased the limit to 4GB.
- If your game uses more than 200 MB on disk, you should break it into smaller parts and use On Demand Resources. For On Demand Resources support in Unity please refer to the On Demand Resources section below. Note that Bitcode is included with tvOS builds, which adds ~130 MB to your executables. This added size is not accounted for in distribution size, as it is be stripped by App Store servers. You can estimate Bitcode size by analyzing LLVM sections in your executable from the command line with otool -l.