Top of tray will generally have a very slightly smaller length than stated size of tray because most trays are tapering.
In other words, a 900mm tray will likely be perhaps 890/895 mm at top, but 900 at base approx. Although trays vary.
So the finished opening (finished Plaster or boarding) for a 900 tray should be okay at 900mm, but would be perfect a few mm less.
You want the top of the tray obviously to be fairly tight to the finished wall surface usually.
I know of one of the big sheds bathroom salesgirl told a friend of mine that their shower tray couldn't fit as the architects plan showed space for tray was a few mm less! :smile: