Does a creature provoke opportunity attacks while riding a carpet of flying?

Question

The carpet of flying says:

You can speak the carpet's command word as an action to make the carpet hover and fly. It moves according to your spoken directions, provided you are within 30 feet of it.

If a creature is riding this carpet and leaves the reach of an enemy creature, do they provoke an opportunity attack from them? Specifically, does using an action to command the carpet to move (which then moves you) count as using your action to move for the purposes of provoking an opportunity attack?

Answer 1

No, because the Action is not used to move

If you had to use your Action to make the carpet fly, then you definitely would provoke an opportunity attack, because you only avoid that when:

you teleport or when someone or something moves you without using your movement, action, or reaction. (PHB, p. 195)

However, the consensus is that a carpet of flying does not require your Action to move, but rather to activate. The spoken directions you deliver to it are not an action, but something you can do in your turn without spending any resources since:

Your turn can include a variety of flourishes that require neither your action nor your move.

You can communicate however you are able, through brief utterances and gestures, as you take your turn. (PHB, p. 190)

The Carpet Doesn't Provoke Opportunity Attacks Either

If you considered a carpet's rider to be "mounted" on the carpet, one might be tempted to make the argument that the carpet itself provokes an Opportunity Attack, and the rider would then be attackable as well since:

if the mount provokes an opportunity attack while you’re on it, the attacker can target you or the mount. (PHB, p. 198)

However, a carpet of flying is an item, not a creature. And the rules state:

You can make an opportunity attack when a hostile creature that you can see moves out of your reach. (PHB, p. 195, bold added)

Thus the carpet does not provoke opportunity attacks itself.

Answer 2

Moving the carpet does not take an action and thus no opportunity attacks are provoked

You can speak the carpet's command word as an action to make the carpet hover and fly. It moves according to your spoken directions, provided you are within 30 feet of it.

The action and the command word are only to make activate the magic item, not to move it around.¹ The second sentence says that all you have to do is speak and the carpet will move accordingly. Since no action cost is listed as being associated with these spoken directions it follows that no action of any kind is needed to perform them.

Thus, this situation falls into the last case outline by the rules for Opportunity Attacks which say:

You also don't provoke an opportunity attack when you teleport or when someone or something moves you without using your movement, action, or reaction.

Since the carpet is moving you without the rider using movement, action, or reaction then this is a clear case where the rules say that an OA is not provoked by the rider.

Note that the carpet cannot provoke OAs since it is an object (see the sidenote to this answer for more details on this) so it also does not get any OAs.

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^{1 - Thanks @PlayPatrice for pointing this out to me in their answer and the comments to it.}

Answer 3

No, (RAW) The creature has not moved so does not provoke an attack of opportunity while on a moving platform (flying carpet).

However, it can be argued that the carpet itself is subject to an attack of opportunity

The character uses a command word (action) to animate the object. Thereafter, moving the carpet is a free action (spoken words). They can move the carpet within 30 feet without standing on the carpet, and then take a move. This means the character can also stand on or off the carpet, not move, and cause the carpet to move.

After that you have two possible interpretations:

• Treat the carpet as a moving platform (No AOA's against the carpet, no extended rules)
• Treat the carpet as a mount

In the first case, it's a moving platform. No Attacks of opportunity can be made against the carpet or the player so long as the player does not move on the carpet. This would be a RAW interpretation as there is no explicit evidence of a carpet being explicitly ruled into either an animated construct or mount.

Another interpretation could rule the carpet as being mounted and thus be treated as an animated object. This would cause the carpet to act as a mount, following mounted combat rules. The interpretation is up to the DM. Note that with a large enough carpet, it would cost 5ft of movement to move from the front of the carpet to the back of the carpet (5ft x 7ft or larger).

With mounted combat, the rider isn't moving, and still has access to all of their movement as part of a move action, though mounting and dismounting requires a large expenditure of total movement. If using the mounted combat rules as an interpretation, the mount itself would incur an attack of opportunity if it moves out of a threatened space.

if the mount provokes an opportunity attack while you’re on it, the attacker can target you or the mount. (PHB, p. 198)

Also something else to consider from mounted combat:

If an effect moves your mount against its will while you're on it, you must succeed on a DC 10 Dexterity saving throw or fall off the mount, landing prone in a space within 5 feet of it. If you're knocked prone while mounted, you must make the same saving throw.

From here we would need to determine the base stats of the carpet. One method would be to pull from the Animate Objects spell and treating it as a medium or large animated object. (HP: 40, AC: 13, Str: 10, Dex: 12 - Medium) / (Large - HP: 50, AC: 10, Str: 14, Dex: 10 - Large).

Overall - with this interpretation rules are vague and you will need to work with the DM regarding the specifics of how to handle mounted flying carpet combat

Above was my suggestion on how to handle the extended implications. But to reiterate the core of you question:

Standing on the carpet and telling the carpet to move, does not expend the users move action or allow for opportunity attacks. Activating the carpet requires an action, telling the carpet to move on subsequent actions is a free action. Rules as written the carpet is a moving platform and does not itself - provoke attacks of opportunity.