Yes, DLLs count, if they are in package with game. If it's a part of OS (like DirectX, .NET Framework etc.), then it doesn't count. Please take a look at 96 kB games made for breakpoint parties: 2003, 2004, 2005, 2006, 2007, 2008, 2009, 2010
Maybe 96kb breakpoint games are not the best examples: klamrisk (2010): 69kb binary + 821kb of dlls; spidr (2009): 96kb binary + 314kb dll; beaniefight (2008): 96kb binary + ~250kb other files; subzero (2005) 252kb of assets.