On Wednesday, the UK’s Advertising Standards Authority (ASA) ruled against Midnite after an investigation into a paid advertisement on TikTok. This ad featured an AI-generated character who appeared to be younger than 25 and was engaged in gambling behavior.
The ASA examined a clip posted to TikTok in July that promoted Midnite, an online casino app based in Gibraltar. The advertisement showed a young man using the app while a voiceover proclaimed: "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 specifically prohibits the depiction of anyone who appears to be under 25 engaging in gambling or taking a prominent role in such ads. The regulator determined that the character’s youthful appearance, along with his casual attire and enthusiastic demeanor, suggested that he was likely in his late teens or early twenties.
As a result, the ad violated rule 16.3 of the CAP Code (Edition 12).
Midnite’s operator, Dribble Media Ltd, stated that they did not authorize the ad. They pointed to inconsistencies in branding and noted that the content was created and distributed by Limay Media Ltd, an affiliate, without Midnite’s approval. In response, Midnite confirmed it had ended its contract with Limay and would enhance compliance reminders for its partners.
Limay Media admitted that the character in the ad was AI-generated rather than a real person. The company claimed that the intention was for the character to appear adult-like. Limay acknowledged failures in its internal approval process, called the error isolated, and reported that the ad was removed within a few hours.
To address these issues, Limay announced that it would implement new safety protocols for AI-generated gambling advertisements. These measures include age-related prompts and reviews to assess the perceived age of AI outputs.
Despite these changes, the ASA concluded that the character's age was not reliably verified. The prompts for generating the AI image did not specifically require the character to be 25 or older. Without any independent verification, the ASA ruled that the character still "seemed to be under 25."
The ASA's ruling instructed both Dribble Media and Limay Media to ensure that the offending advertisement would not be shown again in the same form.
This ruling marked the third time this year that Midnite faced scrutiny from the ASA. Last month, it responded to complaints about an ad that implied gambling could serve as an escape from personal issues. The ASA received 125 complaints regarding that advertisement and ordered its removal. Another ruling from June was not upheld.
In a separate examination, the ASA looked into display ads for White Hat Gaming’s Casimba and The Grand Ivy Casino, which appeared on HLTV.org, a site focusing on e-sports. In March 2026, two banner ads promoted a “100% match bonus up to £100 on 1st deposit” while displaying the required 18+ logo alongside live match coverage featuring betting odds.
A complaint raised concerns that these ads were aimed at under-18s. White Hat Gaming voluntarily paused the ads during the investigation, asserting that HLTV’s audience primarily consists of adults who engage in professional competitive gaming, not casual players, who would generally attract a younger demographic. HLTV supported this assertion by describing its audience as adult-focused.
The ASA evaluated whether the advertisements were targeted at under-18s based on their content or placement. Rules prohibit advertising in media where over 25% of the audience might be under 18 years old. Although audience data did not define the age demographics precisely, the ASA noticed small percentages of under-18s in HLTV’s social media channels but concluded that the content and presentation of the website were clearly aimed at an adult audience. Therefore, the ASA ruled that the ads did not breach CAP Code rules 16.1 or 16.3.13 and took no further action.
