On Wednesday, the UK Advertising Standards Authority (ASA) issued a ruling against Midnite after examining a TikTok advertisement featuring an AI-generated character that appeared to be younger than 25 and involved in gambling activities.
The ASA's review focused on a video released in July that promoted Midnite, a Gibraltar-based online casino app. The ad showcased a young-looking man using the app alongside 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."
According to the ASA’s Code for gambling advertising, individuals who “were, or seemed to be, under 25 years of age” should not be depicted gambling or portrayed significantly in advertisements. The regulator concluded that the character's youthful facial features and demeanor gave the impression that he was in his late teens or early twenties, violating rule 16.3 of the CAP Code (Edition 12).
Midnite’s operator, Dribble Media Ltd, stated that it did not authorize the ad, noting discrepancies in branding and asserting the content was created by an affiliate, Limay Media Ltd, without its consent. Following the ASA's ruling, Midnite confirmed it had ended its contract with Limay and plans to reinforce compliance expectations among its partners.
Limay Media acknowledged that the character in question was a fictional, AI-generated figure rather than a real person, claiming the intention was to depict an adult. The company admitted to failures in its internal approval process, called the mistake an isolated case, and reported that the ad was removed within hours of posting.
Despite implementing new safety measures for AI-generated advertisements, Limay's prompts did not adequately ensure that the character appeared to be aged 25 or older, leading the ASA to conclude that the character still “seemed to be under 25”. As a result, the ASA directed both Dribble Media and Limay Media to prevent the advertisement from reappearing in its current form.
This marks Midnite’s third ruling from the ASA in 2023. Last month, an advertisement drew 125 complaints for suggesting that “gambling was an escape from personal problems,” which led to the ad's removal. A separate ruling in June was not upheld.
In a different ruling, the ASA reviewed display ads from White Hat Gaming’s Casimba and The Grand Ivy Casino brands, which ran on HLTV.org, a site focused on Counter-Strike 2 esports, in March 2026. Two banner ads promoted a “100% match bonus up to £100 on 1st deposit” and included the mandatory 18+ logo. A complaint was filed asserting that these ads were targeted at those under 18.
White Hat Gaming temporarily halted the ads during the investigation and argued that HLTV’s audience is mainly adult and geared towards competitive gaming, which typically attracts older players. HLTV supported this assertion by emphasizing its adult-oriented content.
The ASA assessed whether these ads were aimed at under-18s based on their placement or content, remembering that ads must not target media where more than 25% of the audience is likely to be under 18. While some under-18 demographic presence was recorded in HLTV’s social channels, the ASA concluded the content and presentation were clearly directed at adults, ruling that the ads did not breach CAP Code rules 16.1 or 16.3.13 and took no further action.
