Simple Q&A D&D 3.5 (by RAW) XX

[Jasdoif]

A958 dissent.

I'm afraid it is not a safe assumption, the key word "attack" refers to the rules on actions in combat.

Unless the character is groping with their weapon or has an "armed" unarmed attack in accordance with the list above, waving your hands in the face of an invisible character, hoping to find them, will provoke an attack of opportunity.

Hmm....While I can see what why you might come to conclusion, we're not making an unarmed attack here, because we aren't making an attack.

The closest equivalent action to a general touch attack would be a spellcaster delivering a touch spell (as a touch spell may be delivered on a round other than the one it is cast in, so the touch attack would be standalone), which as you listed does not provoke an attack of opportunity.

Personally, I'm blaming the confusion on the overuse of the word "attack" in the rules.