We investigate the spin-independent part of the virtual Compton scattering (VCS) amplitude off the nucleon within the framework of chiral perturbation theory. We perform a consistent calculation to third order in external momenta according to Weinberg’s power counting. With this calculation we can determine the second- and fourth-order structure-dependent coefficients of the general low-energy expansion of the spin-averaged VCS amplitude based on gauge invariance, crossing symmetry, and the discrete symmetries. We discuss the kinematical regime to which our calculation can be applied and compare our expansion with the multipole expansion by Guichon, Liu, and Thomas. We establish the connection of our calculation with the generalized polarizabilities of the nucleon where it is possible.