A ROM (read-only memory) typically stores 1's and 0's by the presence or absence of a transistor for each bit. So the more 1's you have, the more transistors. It's inconvenient for the transistor count to change with the data, so "transistor sites" are usually counted.
This image shows a closeup of the 8086's microcode ROM. It is arranged as a uniform grid. The regions of doped silicon form transistors (or not).
A closeup of the 8086's microcode ROM shows transistors (T) and empty sites (X). This region has 12 real transistors but would be counted as 18 transistor sites. The complete microcode ROM has 7694 empty sites that bump up the published count.