UK’s Advertising Standards Authority upheld complaint against Midnite over TikTok ad featuring AI-generated character appearing under 25 while gambling.
ASA Midnite AI TikTok ad violates CAP Code rule 16.3. Character’s youthful features, casual styling, and excited demeanour suggested late teens or early twenties age. Midnite terminated affiliate Limay Media Ltd contract.
- ASA Ruling Details
- AI Character Age Verification
- Limay Media Response
- Midnite’s Third ASA Ruling
AI-generated character appearing under 25 in gambling ad violates UK advertising standards. The ASA ruled against Midnite Wednesday following investigation into paid TikTok advertisement posted July. White Hat Gaming also faced review for age-restricted promotion but ruling was not upheld. The clip displayed young-looking man using app with voiceover promoting World Cup betting offer. Midnite confirmed it terminated contract with Limay Media Ltd affiliate. The operator will reinforce compliance reminders to partners following the investigation.
ASA Ruling Details
The ASA reviewed July TikTok clip promoting Midnite, a Gibraltar-based online casino app. The advertisement featured young-looking man using app with voiceover: “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 ASA’s Code for gambling advertising, anyone who was or seemed under 25 years of age must not be depicted gambling or playing significant role in advertisements. The regulator concluded central figure’s youthful facial features, casual styling and excited demeanour gave impression he was in late teens or early twenties. The ad violated rule 16.3 of CAP Code Edition 12. This is Midnite’s third ASA ruling this year. Last month operator faced scrutiny for ad suggesting gambling was escape from personal problems. The ASA received 125 complaints on offending ad and company ordered to remove advertisement. Another June ruling was not upheld.
AI Character Age Verification
Limay Media acknowledged person depicted was AI-generated fictional character rather than real individual. The company claimed design was intended to appear as adult. Despite this assertion, the ASA found character’s age was not credibly verified. The prompts used to generate AI image did not explicitly require character to appear aged 25 or over. Without independent verification process, regulator determined character still seemed to be under 25. According to AGBrief, this case sets precedent for AI-generated content regulation across UK gambling sector. The ASA’s ruling directed both Dribble Media and Limay Media to ensure offending advertisement would not be redisplayed in same form. This enforcement action reflects growing regulatory scrutiny over AI marketing tools in gambling advertising.
Midnite’s operator Dribble Media Ltd stated ad had not been authorised by their company. They cited discrepancies in branding and asserted it was created and disseminated by affiliate Limay Media Ltd without Midnite’s approval. Limay Media acknowledged error was isolated and noted ad was removed within few hours. The company admitted lapses in internal approval process. Limay reported implementing new safety measures for AI-generated gambling creatives. These include specifying age-related prompts and reviewing perceived age of AI outputs. Despite these measures, the ASA found character’s age was not credibly verified. The ruling demonstrates regulators will hold operators accountable for affiliate actions.
Limay Media Response
Limay Media acknowledged person depicted was AI-generated fictional character rather than real individual. The company claimed design was intended to appear as adult. Despite this assertion, the ASA found character’s age was not credibly verified. The prompts used to generate AI image did not explicitly require character to appear aged 25 or over. Without independent verification process, regulator determined character still seemed to be under 25. This case highlights challenges regulators face with AI-generated content. The prompts used to generate AI image did not explicitly require character to appear aged 25 or over. Without independent verification process, regulator determined character still seemed to be under 25. The company admitted lapses in internal approval process. Limay reported implementing new safety measures for AI-generated gambling creatives. These include specifying age-related prompts and reviewing perceived age of AI outputs. Despite these measures, the ASA found character’s age was not credibly verified.
Midnite’s Third ASA Ruling
This is Midnite’s third ASA ruling this year. Last month operator came under scrutiny for ad suggesting gambling was escape from personal problems. The ASA received 125 complaints on offending ad and company ordered to remove advertisement. Another June ruling was not upheld. In separate case, ASA examined display advertising for White Hat Gaming’s Casimba and The Grand Ivy Casino brands. These appeared on HLTV.org specialist Counter-Strike 2 e-sports website in March 2026. Two banner ads promoted 100% match bonus up to £100 on 1st deposit and displayed mandatory 18+ logo. The ads appeared alongside live match coverage featuring betting odds and sponsor logos including link to Casimba website. A complaint suggested such placements were inappropriately targeted at under-18s. White Hat Gaming paused ads during investigation and argued HLTV’s audience is primarily adult and focused on professional competitive gaming rather than casual play which tends to attract minors. HLTV corroborated this highlighting editorial tone as adult-oriented. The ASA reviewed whether ads were directed at under-18s through placement or content. Its rules prohibit advertising through media where more than 25% of audience is likely to be under 18. While audience data did not conclusively define website’s age demographics, regulator noted small percentages of under-18s in HLTV’s social channels but found website’s content and presentation clearly targeted adults. Ultimately ASA ruled ads did not breach CAP Code rules 16.1 or 16.3.13 and took no further action.
Frequently Asked Questions
Why did ASA rule against Midnite’s TikTok ad?
The ad featured AI-generated character appearing under 25 in gambling promotion, violating CAP Code rule 16.3 on age depiction in gambling advertising.
What age verification did the ASA require?
The character’s youthful features, casual styling, and excited demeanour suggested late teens or early twenties, failing to meet age 25 minimum requirement.
Did Midnite authorise the TikTok advertisement?
Midnite stated ad was created and disseminated by affiliate Limay Media Ltd without approval, and terminated the contract following the investigation.
What safety measures did Limay Media implement?
Limay reported implementing age-related prompts and reviewing perceived age of AI outputs for future AI-generated gambling creatives.
Why was White Hat Gaming’s case not upheld?
The ASA found HLTV.org’s content and presentation clearly targeted adults despite small under-18 percentages on social channels.
This article has been thoroughly researched and reviewed by the CasinoBait editorial team to ensure accuracy and relevance for Asian casino players.
