No, that is not correct. According to 41 CFR 60-1.40, which covers Affirmative Action Programs, the employee minimum for supply and service contractors which requires a written AAP is 50 employees.
You can use this OFCCP audit checklist to ensure you're doing what is required to maintain OFCCP's regulations including VEVRAA, Section 503, and EO 11246. Or request a demo to streamline your compliance and recruiting efforts.