[RPG] Without Improved Unarmed Strike, does an improved disarm attempt provoke attacks of opportunity

dnd-3.5efeatsopportunity-attack

A PC wields a 1-handed weapon one-handed. He wants to make a disarm attempt with his empty hand. The PC possesses the feat Improved Disarm but not the feat Improved Unarmed Strike or any other similar ability.

I think that the PC provokes an attack of opportunity for making the disarm attempt unarmed. Put simply, I read disarm as an attack.

The PC's player claims that his PC does not provoke an attack of opportunity for three reasons:

  1. A disarm is not an attack as such, but an attack-equivalent action, which he simply interprets as a standard action.
  2. The Improved Disarm feat overrules the unarmed strike rules in this particular case.
  3. The PC's considered armed because the PC's still wielding a melee weapon.

Who's right?

Best Answer

There's no attack of opportunity.

This is a case of specific-beats-general. Improved Disarm is unambiguous:

You do not provoke an attack of opportunity when you attempt to disarm an opponent.

Yes, disarming is a melee attack (disarm rules say that you do it "as a melee attack", not "instead of a melee attack" or similar), and an unarmed disarming attack is an unarmed melee attack. But the character is performing an unarmed melee attack as an attempt to disarm an opponent, and Improved Disarm clearly states that this doesn't provoke an attack of opportunity.