The UK’s Advertising Standards Authority (ASA) delivered a ruling against Midnite on Wednesday after reviewing a paid advertisement on TikTok that featured an AI-generated character, perceived to be under 25 years old, participating in gambling activities.
The ASA examined the promotional video posted in July for Midnite, an online casino app based in Gibraltar. The advertisement showcased a young man 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.”
According to the ASA’s gambling advertising code, anyone who appears to be under 25 is prohibited from being shown gambling or playing a significant role in such advertisements. The ASA determined that the character’s youthful appearance, stylish casual attire, and enthusiastic behavior suggested he was in his late teens or early twenties.
Consequently, the ad was found to be in violation of rule 16.3 in the CAP Code (Edition 12). Dribble Media Ltd, the operator of Midnite, stated that they had not authorized the advertisement, citing brand discrepancies and asserting that it was generated and released by an affiliate, Limay Media Ltd, without prior approval. They also confirmed the termination of their agreement with Limay while pledging to strengthen compliance communications with their partners.
Limay Media recognized that the character in question was AI-generated rather than a real person and claimed that the design aimed to depict an adult. The company acknowledged failures in its internal review process, termed the incident an isolated mistake, and noted that the advertisement was removed within hours.
Limay reported implementing new protocols for AI-generated gambling advertisements, which include age-specific prompts and reviewing the perceived age of AI outputs. However, the ASA found that the character’s age remained unverified and noted that the prompts used for generating the AI image did not ensure that it appeared to be at least 25 years of age. As a result, the regulator maintained that the character still “seemed to be under 25.”
The ASA instructed both Dribble Media and Limay Media to refrain from redisplaying the advertisement in its current form. This ruling marks Midnite’s third adjudication from the ASA this year; last month, the company faced criticism for an advertisement that implied gambling could serve as an escape from personal challenges, leading to 125 complaints and a directive to remove the ad. Another ruling in June was not upheld.
In a separate case, the ASA examined display ads for White Hat Gaming’s Casimba and The Grand Ivy Casino brands, which had run on HLTV.org, a Counter-Strike 2 e-sports site, in March 2026. Two banner ads advertised a “100% match bonus up to £100 on 1st deposit” while including the required 18+ logo. These ads were positioned adjacent to live match coverage that featured betting odds and sponsorship links, including one for Casimba.
A complaint alleged that these placements were improperly targeted towards those under 18. During the ASA’s investigation, White Hat Gaming paused the ads and contended that HLTV’s audience primarily comprises adults interested in competitive gaming rather than casual gaming, which typically draws a younger crowd. HLTV supported this assertion, emphasizing its adult-oriented editorial stance.
The ASA evaluated whether the ads appealed to individuals under 18 based on placement or content, adhering to rules that bar advertising in media where over 25% of the audience might be underage. Although the audience figures did not definitively clarify demographics, the regulator noted the minimal occurrence of under-18s among HLTV’s social channels, determining that the content and presentation of the website were clearly aimed at adults.
Ultimately, the ASA concluded that the advertisements did not violate rules 16.1 or 16.3.13 of the CAP Code and took no further action.
