Had a similar thought. In theory, you're right, though in practice today it's "256 bytes of binary plus X MB of DOS emulator".
Unless I'm overlooking something, the demo only requires DOSBox to have a machine with predefined execution speed. There are no DOS interrupt calls that I can see. Other than that, the program could probably even be trivially modified to fit in a floppy disk MBR and could potentially run without underlying OS.
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But there's nothing stopping you running it on a real DOS machine.
I expect someone will then say "though in practice today it's 256 bytes of binary plus a whopping 64kB of BIOS ROM and 16kB of video RAM" ;-)