The sub-leading power of the scattering amplitude for deeply-virtual Compton scattering (DVCS) off the nucleon contains leading-twist and twist-3 generalized parton distributions (GPDs). We point out that in DVCS, at twist-3 accuracy, one cannot address any individual twist-3 GPD. This complication appears on top of the deconvolution issues familiar from the twist-2 DVCS amplitude. Accessible are exclusively linear combinations involving both vector and axial-vector twist-3 GPDs. This implies, in particular, that the (kinetic) orbital angular momentum of quarks can hardly be constrained by twist-3 DVCS observables. Moreover, using the quark-target model, we find that twist-3 GPDs can be discontinuous. The discontinuities however cancel in the DVCS amplitude, which further supports the hypothesis of factorization at twist-3 accuracy.