The following are the rules for making an attack with a touch spell from touch spells in combat. I have bolded the statements which I wish to focus on.

Many spells have a range of touch. To use these spells, you cast the spell and then touch the subject. In the same round that you cast the spell, you may also touch (or attempt to touch) as a free action. You may take your move before casting the spell, after touching the target, or between casting the spell and touching the target. You can automatically touch one friend or use the spell on yourself, but to touch an opponent, you must succeed on an attack roll.

Touch Attacks: Touching an opponent with a touch spell is considered to be an armed attack and therefore does not provoke attacks of opportunity. The act of casting a spell, however, does provoke an attack of opportunity. Touch attacks come in two types: melee touch attacks and ranged touch attacks. You can score critical hits with either type of attack as long as the spell deals damage. Your opponent's AC against a touch attack does not include any armor bonus, shield bonus, or natural armor bonus. His size modifier, Dexterity modifier, and deflection bonus (if any) all apply normally.

Holding the Charge: If you don't discharge the spell in the round when you cast the spell, you can hold the charge indefinitely. You can continue to make touch attacks round after round. If you touch anything or anyone while holding a charge, even unintentionally, the spell discharges. If you cast another spell, the touch spell dissipates. You can touch one friend as a standard action or up to six friends as a full-round action. Alternatively, you may make a normal unarmed attack (or an attack with a natural weapon) while holding a charge. In this case, you aren't considered armed and you provoke attacks of opportunity as normal for the attack. If your unarmed attack or natural weapon attack normally doesn't provoke attacks of opportunity, neither does this attack. If the attack hits, you deal normal damage for your unarmed attack or natural weapon and the spell discharges. If the attack misses, you are still holding the charge.

Attack roll

An attack roll represents your attempt to strike your opponent on your turn in a round. When you make an attack roll, you roll a d20 and add your attack bonus. (Other modifiers may also apply to this roll.) If your result equals or beats the target's Armor Class, you hit and deal damage.

Its the first paragraph which I would like to draw your attention to. Specifically that in the round you cast the spell, you may touch or attempt to touch as a free action, however enemies still require an attack roll. Its not till the rounds after while holding the charge that its a standard action to make touches. While looking at the attack roll it makes no mention of an action, since attack rolls are part of many types of actions from standard, full, and even free as in the case of attacks of opportunity.

So with this wording, you should be allowed to safely cast a spell while outside of someone threatened area, walk upto an enemy (which may provoke an AOO, depending on you and them), and just stand there trying to touch them with free actions until you finally manage to hit them. Keep in mind that making attacks with a touch spell does not provoke.

So is this actually how it should work according to RAW (but not RAI), or have I missed a rule somewhere which changes this?