The UK’s Advertising Standards Authority (ASA) announced on Wednesday that it found against Midnite following an examination of a TikTok advertisement featuring an AI-generated character, who appeared to be under 25, engaging in gambling activity.
The ASA reviewed a promotional clip from July that showcased a seemingly young man using the Midnite app, which is run by Gibraltar-based Dribble Media Ltd. The ad included a voiceover that stated, "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 are, or appear to be, under 25 cannot be shown gambling or playing significant roles in such advertisements. The ASA determined that the character's youthful appearance, casual style, and exuberance suggested he was likely in his late teens or early twenties.
Consequently, the ad was found to have breached rule 16.3 of the CAP Code (Edition 12). Dribble Media Ltd contended that the advertisement had not received official authorization from the company, highlighting branding inconsistencies and claiming it had been produced and released by an affiliate, Limay Media Ltd, without Midnite’s consent.
In response to the ruling, Midnite confirmed that it had ended its relationship with Limay and would heighten compliance reminders to its partners. Limay Media acknowledged that the character featured in the ad was AI-generated and claimed the intention was to depict an adult. However, they conceded that they had failed to follow proper internal approval standards, labeling the mistake a one-off occurrence and stated that the advertisement was removed shortly after it was posted.
The company mentioned that it has implemented new safeguards for AI-generated gambling advertisements, including age-related prompts and evaluations of the perceived age of AI outputs. Despite these steps, the ASA ruled that the character's age had not been convincingly verified. The prompts used in the AI generation process failed to specify an age of 25 or older. Lacking an independent verification mechanism led the regulator to conclude that the character still appeared to be under 25.
The ASA’s decision requires both Dribble Media and Limay Media to ensure the advertisement is not displayed in its current form again.
This ruling marks Midnite’s third encounter with the ASA this year. In a prior ruling last month, the operator faced criticism for an advertisement suggesting that gambling could serve as an escape from personal problems, receiving 125 complaints, leading to a directive for removal. A separate ruling in June was not upheld.
In a different case, 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 two banner advertisements offered a “100% match bonus up to £100 on 1st deposit” and adhered to mandatory age restrictions by featuring the required 18+ logo.
A complaint was lodged, alleging that the ads were improperly targeted towards under-18 individuals. During the investigation, White Hat Gaming suspended the ads, arguing that HLTV's audience is predominantly adult, focusing on professional competitive gaming, which is less appealing to minors.
HLTV supported this position, emphasizing its adult-oriented editorial tone. The ASA assessed whether the ads targeted under-18s through their placement or content and referenced rules that restrict advertising where more than 25% of the audience is likely to be under age 18.
Although audience data did not definitively clarify the demographics for HLTV’s website, the ASA noted the presence of small proportions of under-18s in its social media channels but recognized that the overall content and presentation clearly aimed at adults. Thus, the ASA concluded that the advertisements did not violate CAP Code rules 16.1 or 16.3.13, deciding not to take further action.
