We investigate the low-energy behavior of the four-point Green's function ⌫ describing virtual Compton scattering off the nucleon. Using Lorentz invariance, gauge invariance, and crossing symmetry, we derive the leading terms of an expansion of the operator in the four-momenta q and qЈ of the initial and final photon, respectively. The model-independent result is expressed in terms of the electromagnetic form factors of the free nucleon, i.e., on-shell information which one obtains from electron-nucleon scattering experiments. Modeldependent terms appear in the operator at O(q ␣ q  Ј ), whereas the orders O(q ␣ q  ) and O(q ␣ Ј q  Ј ) are contained in the low-energy theorem for ⌫ , i.e., no new parameters appear. We discuss the leading terms of the matrix element and comment on the use of on-shell equivalent electromagnetic vertices in the calculation of ''Born terms'' for virtual Compton scattering. ͓S0556-2813͑96͒02108-5͔