Carboxymethyl chitosan (CMCh) is an ampholytic chitosan derivative that manifests versatile applications in food industry, such as antibacterial ingredients and nutritional additives. However, its use as a cryoprotectant remains under-researched. In this study, the cryoprotective effect of CMCh oligosaccharide (CMCO) on frozen surimi (silver carp) was systematically investigated in terms of protein structures, gelling behaviors, and sensory qualities. CMCO (0.6%) was incorporated in the surimi before frozen storage (−18 °C for 60 days) while the commercial cryoprotectant (4% sucrose, 4% sorbitol) was used as a positive control. Results indicated that CMCO could inhibit the freezing-induced denaturation of myofibrillar protein, whose values of solubility, Ca2+-ATPase and sulfhydryl content were 24.8%, 64.7%, and 17.1% higher than the nonprotected sample, respectively, while the surface hydrophobicity was 21.6% lower. Accordingly, CMCO stabilized microstructure of the surimi gels associated with improved gel strength, viscoelasticity, water-holding capacities, and whiteness. Moreover, the cryoprotective effect of CMCO with higher degree of carboxymethyl substitution (DS: 1.2) was more pronounced than that of low-DS-CMCO (DS: 0.8). Frozen surimi treated with high-DS-CMCO achieved competitive gelling properties and sensory acceptability to those with the commercial counterpart. This study provided scientific insights into the development of ampholytic oligosaccharides as food cryoprotectants.