ASA Upholds Complaint Over Midnite Affiliate's TikTok Ad
The Advertising Standards Authority has upheld a complaint against a paid TikTok ad linked to sports betting app Midnite after ruling that its AI-generated central character appeared to be under 25 years old, breaching UK gambling advertising rules.
What The Ad Showed
The ad, a paid-for TikTok post seen on July 3, 2026, showed a man using a gambling app on his phone who said: "Another massive World Cup upset. Bet £10 on the big match and get £30 in the free bets. Level up your World Cup with Midnite, get on it," according to the ASA's published ruling.
Dribble Media Ltd, which trades as Midnite, told the ASA the ad had not been sanctioned by the company and that it had not contracted the ad's creator, an affiliate called Limay Media, to publish paid social posts on its behalf. Midnite said it had since ended its contract with Limay Media and would remind its remaining affiliates of their obligations under the CAP Code.
Limay Media told the regulator the character was entirely AI-generated, based on no real person's image or footage, and had been intended to depict an adult. It said its usual process required managerial and client sign-off before publishing gambling ads, but that step was skipped in this case due to what it called "an isolated human error," and that the ad was removed within a few hours once a manager spotted it.
Why The ASA Upheld The Complaint
The ASA said it had "seen no evidence" that the prompt used to generate the character specified an age of 25 or over, and found the figure's "youthful facial features, smooth skin and a boyish hairstyle," combined with a "casual and youthful presentation" and animated, excited mannerisms, created the impression of someone in his late teens or early twenties.
"Although the video used was AI-generated, we considered the overall impression created by the individual depicted was that he seemed to be under 25," the regulator concluded, ruling the ad breached CAP Code rules 16.3 and 16.3.14 on gambling advertising.
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What The Ruling Requires
The ASA ordered that the ad "must not appear again in the form complained of" and told both Dribble Media and Limay Media to ensure gambling ads do not feature anyone who is, or appears to be, under 25 in future, including AI-generated characters.
The ruling is one of the first UK gambling-advertising decisions to turn specifically on the perceived age of a wholly AI-generated character, and comes as the ASA's Active Ad Monitoring system, which uses AI to scan for potentially breaching ads, continues to surface a growing share of gambling ad investigations without a consumer complaint being filed first.
