ASA upholds complaint against Midnite over AI-generated character in TikTok ad

UK gambling ads are back under the microscope after the Advertising Standards Authority (ASA) upheld a complaint about a paid TikTok promotion for Midnite that used an AI-generated character who appeared to be under 25 while gambling.

The ASA reviewed a clip posted to TikTok in July that promoted the Gibraltar-based online casino app Midnite. In the video, a young-looking man is shown using the app while a voiceover says: “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.”

Under the ASA’s gambling advertising rules, anyone who “was, or seemed to be, under 25 years of age” must not be shown gambling or playing a significant role in an ad. The regulator decided the central figure’s facial features, casual styling, and excited demeanor made him look like he was in his late teens or early twenties.

Midnite’s operator, Dribble Media Ltd, told the ASA the ad wasn’t authorised by the company. Dribble said there were branding discrepancies and that the ad was created and distributed by an affiliate, Limay Media Ltd, without Midnite’s approval.

Limay Media accepted that the person shown was an AI-generated fictional character (not a real individual) and said the design was meant to look like an adult. Limay also acknowledged internal approval failures, called the incident isolated, and said the ad was removed within a few hours. The affiliate said it has since added safeguards for AI-generated gambling creatives, including using age-related prompts and checking the perceived age of AI outputs.

Even so, the ASA found the character’s age wasn’t credibly verified. It noted the prompts used to generate the AI image didn’t explicitly require the person to appear 25 or over, and there was no independent verification process. The ruling instructed both Dribble Media and Limay Media to ensure the ad does not appear again in the same form.

The decision adds to Midnite’s regulatory trouble in 2026: this is the operator’s third ASA ruling this year. Last month, the ASA ordered the removal of a Midnite ad that suggested “gambling was an escape from personal problems,” after receiving 125 complaints.

In separate findings, the ASA also looked at display ads for White Hat Gaming’s Casimba and The Grand Ivy Casino brands that appeared on HLTV.org, a Counter-Strike 2 esports site, in March 2026. The two banner ads promoted a “100% match bonus up to £100 on 1st deposit” and included an 18+ logo. While audience data didn’t conclusively define the site’s age breakdown, the ASA considered small under-18 percentages on HLTV’s social channels and ultimately found the website’s content and presentation were clearly aimed at adults, under rules that prohibit gambling ads in media where more than 25% of the audience is likely under 18.