The invention relates to a sucrose-free oil-free gluten-free cake and a production process thereof. The sucrose-free oil-free gluten-free cake is prepared from the following raw materials in parts byweight: 12-25 parts of almond powder, 0.5-3 parts of coconut flour, 2-5 parts of rice flour, 0.2-1 part of linseed powder, 0.5-2 parts of inulin, 13.02-26.6 parts of compound sugar, 0.2-0.5 part of potassium hydrogen tartrate, 30-50 parts of egg white, 20-30 parts of egg yolk and 20-37 parts of milk. The cake is not added with any animal and vegetable oil, sucrose and raw material containing gliadin and glutenin, and is a true oil-free, sucrose-free and gluten-free product. Moreover, the process uses non-traditional pastry ingredients such as the almond powder and the coconut flour as main materials, and the mouth feel of the product is close to that of traditional cakes, but the cake tastes slightly different from traditional cakes. Under the condition of stable quality assurance, the cake is more abundant in mouth feel, and the finished product is better in color and better in taste.