On Wednesday, the UK’s Advertising Standards Authority (ASA) decided against Midnite following an investigation into a TikTok advertisement that featured an AI-generated character who appeared to be younger than 25 while promoting gambling.
The ASA examined a clip released in July that showcased a young man using the Gibraltar-based online casino app, featuring 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.”
Per the ASA’s Code for gambling advertising, individuals who look younger than 25 should not be shown gambling or playing a key role in such ads.
The authority determined that the character's youthful features, casual clothing, and enthusiastic demeanor suggested he was in his late teens or early twenties, which breached rule 16.3 of the CAP Code (Edition 12).
Dribble Media Ltd, which operates Midnite, claimed the advertisement was not sanctioned by their company. They cited inconsistencies in branding and stated that it was created by Limay Media Ltd, an affiliate, without their approval. Midnite has since ended its relationship with Limay and plans to issue compliance reminders to its partners.
Limay Media confirmed the character was entirely AI-generated and not a real person. They intended for it to appear adult-like but acknowledged flaws in their internal approval process, describing the mistake as isolated and asserting that the ad was taken down within hours. The company is now implementing new protocols for AI-generated gambling advertisements, including age-related prompts and a review of the perceived age of AI outputs.
However, the ASA found that the character's age was not credibly verified. The prompts used for generating the AI image did not explicitly mandate an appearance of 25 or older. Lacking an independent verification process, the regulator still believed the character “seemed to be under 25.”
The ASA ordered both Dribble Media and Limay Media to avoid redisplaying the offending advertisement in its original form. This ruling marks the third one against Midnite by the ASA this year. Just last month, Midnite faced criticism for an advertisement suggesting that “gambling was an escape from personal problems,” which attracted 125 complaints and was ordered to be removed. A previous ruling from June was not upheld.
In a different case, the ASA evaluated display advertisements for White Hat Gaming’s Casimba and The Grand Ivy Casino brands, which had appeared on HLTV.org, a specialized Counter-Strike 2 e-sports website, in March 2026. The two banner ads offered a “100% match bonus up to £100 on 1st deposit” and included the required 18+ logo.
A complaint raised concerns that these ads were improperly targeted at under-18s. White Hat Gaming suspended the ads during the inquiry, arguing that HLTV’s audience primarily consists of adults engaged in professional competitive gaming rather than casual gamers, who tend to be younger. HLTV supported this claim, noting its content was geared towards an adult audience.
The ASA assessed whether the ads targeted under-18s based on their placement or content, as their regulations prohibit advertising in media where over 25% of the audience is under 18. Although the audience data did not definitively establish the website's demographic, the regulator observed minimal under-18 representation on HLTV’s social media but concluded that the site’s content and presentation were aimed at adults.
Ultimately, the ASA determined that the ads did not violate CAP Code rules 16.1 or 16.3.13 and decided to take no further action.
