The UK Advertising Standards Authority has upheld a complaint against Dribble Media, trading as Midnite, over a paid TikTok gambling ad featuring an AI-generated man it judged appeared to be under 25. The regulator ruled that the character was shown gambling and played the central role in promoting a World Cup offer, breaching the CAP Code.
The ad, seen on July 3, showed the man using a gambling app on his phone. Its voiceover 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.”
The CAP Code prohibits anyone who is, or seems to be, under 25 from being shown gambling or playing a significant role in a gambling advertisement. The ASA found that the character’s smooth skin, youthful facial features, boyish hairstyle, grey hoodie and animated, excited manner created the impression of someone in their late teens or early twenties.
The fact that the figure was fictional did not alter that assessment. The ASA acknowledged Limay Media’s position that the individual was AI-generated and intended to represent an adult, but said there was no evidence that the generation prompt had required a character who appeared to be at least 25.
Midnite said it had not authorised the creative and disputed that the branding was its own, despite the use of the Midnite name. It said it investigated the matter and ended its contract with Limay Media, the affiliate responsible for the ad.
Limay said its normal approval process, involving managerial and client sign-off, had not been followed. The company said a manager spotted the problem within hours and paused the ad, then introduced safeguards for AI-generated gambling creatives, including age-specific prompts, perceived-age reviews, restrictions on youthful styling and records of generation and approval decisions.
The ASA said the ad must not appear again in the form complained of, and instructed both Dribble Media and Limay Media to ensure future gambling advertising does not show anyone who is, or appears to be, under 25 gambling or playing a significant role.
The ruling applies an existing age-portrayal rule to synthetic content. The ASA’s online-ad monitoring report found high compliance among gambling ads examined between July and November 2025, although 0.4% were rated red and 3.4% amber for potential age-related concerns. The regulator’s monitoring system captured about 13,000 alcohol and gambling ads during that period and uses AI-based tools to identify emerging risks.
It follows the ASA’s August ban on five Midnite ads that suggested gambling could offer relief from everyday frustrations, as we reported.
CAP has also refreshed guidance on responsibly targeting age-restricted online advertising, while separate ASA guidance has reinforced that advertising rules apply regardless of whether material is made using AI.
