The conjectured bound is best possible, because a regular tournament of order does not contain the oriented tree consisting of a vertex dominating leaves.
Let be the function such that every oriented tree of order is -universal, that is contained in every digraph with chromatic number at least . Burr proved that . This was slightly improved by Addario-Berry et al. [AHL+] who proved .
Burr's conjecture has been proved only in few particular cases of digraphs: tournaments, and acyclic digraphs. Kühn, Mycroft, and Osthus [KMS] showed that every oriented tree of order is contained in every tournament of order for all sufficiently large (so proving a Conjecture of Sumner); Addario-Berry et al. [AHL+] proved that every acyclic digraph with chromatic number contains every oriented tree of order .
Burr's conjecture or some approximation have been also proved for special classes of trees. Gallai-Roy's celebrated theorem states that every directed path of order is -universal; El-Sahili [E] proved that every oriented path of order is -universal and that the antidirected path of order is -universal; Addario-Berry, Havet, and Thomassé [AHT] showed that every oriented path of order whose vertex set can be partioned into two directed paths is -universal; Addario-Berry et al. [AHL+] showed that antidirected trees (oriented trees in which every vertex has in-degree or out-degree ) are -universal.
Havet, generalizing a conjecture of Havet and Thomassé (see [H]) on tournaments, conjectured that the following could also be true.
Bibliography
[AHL+] L. Addario-Berry, F. Havet, C. Linhares Sales, B. Reed, and S. Thomassé. Oriented trees in digraphs. Discrete Mathematics, 313(8):967-974, 2013.
[AHT] L. Addario-Berry, F. Havet, and S. Thomassé, Paths with two blocks in -chromatic digraphs, J. of Combinatorial Theory Ser. B, 97 (2007), 620--626.
* [B] A. Burr, Subtrees of directed graphs and hypergraphs, Proceedings of the Eleventh Southeastern Conference on Combinatorics, Graph Theory and Computing, Boca Raton, Congr. Numer., 28 (1980), 227--239.
[H] F. Havet, Trees in tournaments. Discrete Mathematics 243 (2002), no. 1-3, 121--134.
[KOM] D. Kühn, D. Osthus, and R. Mycroft, A proof of Sumner's universal tournament conjecture for large tournaments, Proceedings of the London Mathematical Society 102 (2011), 731--766.
* indicates original appearance(s) of problem.