On Wednesday, the UK’s Advertising Standards Authority (ASA) ruled against Midnite after investigating a TikTok advertisement that featured an AI-generated character, which appeared to be under 25 years old, participating in gambling activities. The ASA examined a clip posted in July that promoted Midnite, a Gibraltar-based online casino app. In the ad, a seemingly young man was shown using the app, with a voiceover stating: "Another massive World Cup upset. Bet £10 on the big match and get £30 in free bets. Level up your World Cup with Midnite, get on it."
The ASA’s Code for gambling advertising prohibits depicting anyone who "was, or seemed to be, under 25 years of age" gambling or playing significant roles in advertisements. The regulator determined that the character's youthful features, casual attire, and animated demeanor suggested he was in his late teens or early twenties, thus violating rule 16.3 of the CAP Code (Edition 12).
Dribble Media Ltd, the operator for Midnite, responded by stating that the ad had not received their authorization. They pointed to inconsistencies in branding and claimed the advertisement was created and distributed by Limay Media Ltd without their approval. Midnite announced that it has terminated its contract with Limay and emphasized that it would enforce compliance reminders with its partners.
Limay Media acknowledged that the character depicted was AI-generated rather than a real person and insisted it was designed to appear as an adult. The company admitted to failures in its internal approval process and described the incident as isolated. They noted that the ad was removed within hours. Limay has since implemented enhanced safety protocols for AI-generated gambling creatives, including using age-specific prompts and reviewing the perceived ages of AI outputs.
The ASA found that the character’s age was not sufficiently verified; the prompts used for creating the AI image did not specifically require the character to appear aged 25 or older. Without a verification process, the ASA concluded that the character still "seemed to be under 25." As a result, the ASA ruled that both Dribble Media and Limay Media must ensure the advertisement does not reappear in its current form.
This ruling marks Midnite’s third action from the ASA this year. Last month, the company was scrutinized for an ad that implied “gambling was an escape from personal problems,” which attracted 125 complaints and was ordered to be removed. Another ruling in June did not result in action.
In a separate matter, the ASA reviewed display ads for White Hat Gaming’s Casimba and The Grand Ivy Casino brands, which ran on HLTV.org, a Counter-Strike 2 e-sports website, in March 2026. The ads promoted a “100% match bonus up to £100 on 1st deposit” and included the required 18+ logo. They appeared next to live match coverage with betting odds and sponsor logos linking to Casimba’s website.
A complaint was raised arguing that these placements were improperly targeted at individuals under 18. White Hat Gaming suspended the ads during the investigation, asserting that HLTV’s audience is primarily adult and that the site focuses on professional gaming, which typically appeals to older demographics. HLTV supported this claim, emphasizing its adult-oriented editorial approach.
The ASA assessed whether the ads were directed at under-18s based on their placement or content, noting that ads cannot be shown in media where over 25% of the audience is likely to be underage. While demographic data did not conclusively define HLTV’s audience, the ASA acknowledged a small percentage of under-18s on HLTV’s social channels and found that the website’s content was clearly aimed at adults. Ultimately, the ASA ruled that the ads did not breach CAP Code rules 16.1 or 16.3.13, and took no further action.
