UK Ad Watchdog Bans Midnite TikTok Ad Over ‘Under-25’ AI Character

The Advertising Standards Authority (ASA) has upheld a complaint against Dribble Media Ltd, trading as the betting operator Midnite, after ruling that a paid-for TikTok ad featured someone who seemed to be under 25 years of age gambling. The ruling, published on September 16, 2026, requires that the ad must not appear again in the form complained of.

The regulator said the ruling forms part of a wider piece of work on gambling ads. The ad was identified for investigation following intelligence gathered by the ASA’s Active Ad Monitoring system, which uses AI to proactively search for online ads that might break the rules. The ASA publishes its rulings every Wednesday, and the ruling records one complaint.

The ad, seen on July 3, 2026, featured a video of a man using a gambling app on his phone. In the video, he 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 ASA challenged whether the ad breached the CAP Code’s gambling rules because it featured someone who seemed to be, or who was, under 25 years of age.

The Companies’ Responses

Dribble Media told the ASA the ad had not been sanctioned by the company and that the branding used was not its own, despite the word “Midnite” being used. The operator said it had investigated the matter and found the ad had been created by an affiliate, Limay Media, which it had not contracted to publish any paid social media posts. Midnite said it had since ended its contract with Limay Media and would remind its affiliates of the need to comply with contractual requirements and the CAP Code.

Limay Media Ltd said the ad had been created using AI and that the individual shown was an AI-generated fictional character rather than a real person. The affiliate said no source images or footage of a real individual had been used and that no subsequent alterations had been made to the character. It said the prompt used to generate the ad did not specify the character’s age, that the character had been intended to depict an adult, and that there had been no intention to portray a child or young person. Limay Media acknowledged that because the character was AI-generated, there was no underlying real individual whose age could be independently verified.

Limay Media said its usual process for gambling advertising required managerial review and approval before publication, followed by client approval, but that this process had not been followed, which it described as an isolated human error. The affiliate said the ad remained online for only a few hours before a manager identified the issue and immediately paused it, and it apologised for the oversight. It said it had since introduced additional safeguards for AI-generated characters used in gambling ads, including specifying age-related prompts, reviewing characters specifically for perceived age, avoiding styling or facial features that could suggest someone was under 25, and retaining records of the AI-generation and approval process.

Assessment and Breach

The CAP Code provides that no one who is, or seems to be, under 25 years old may be featured gambling or playing a significant role in gambling ads. The ASA noted that the individual was shown throughout the ad on his phone, engaging with a gambling app and appearing excited by the promotional offer. The regulator considered that he was using the app to gamble and was the central focus of the ad.

The ASA acknowledged Limay Media’s position that the character was an AI-generated fictional adult, as well as Midnite’s position that the ad had not been sanctioned. However, the regulator noted that the prompt used to generate the ad did not refer to the character’s age or to the age restrictions applying to gambling advertising, and said it had therefore seen no evidence that AI had been prompted to ensure the character appeared to be aged 25 or over.

Assessing the character’s presentation, the ASA found he had youthful facial features, smooth skin and a boyish hairstyle, and was dressed in a plain grey hoodie that added to a casual and youthful appearance. The regulator said his animated expressions and excited manner were likely to give viewers the impression of someone in his late teens or early twenties, and that nothing in his appearance, styling or behaviour clearly indicated he was older than 25. Although the video was AI-generated, the ASA considered the overall impression created by the individual depicted was that he seemed to be under 25.

The ASA concluded that the ad featured someone who seemed to be under 25 years of age gambling and playing a significant role, and therefore breached rules 16.3 and 16.3.14 of the CAP Code (Edition 12), which govern gambling advertising. Alongside the ban on the ad reappearing, the regulator told both Dribble Media Ltd t/a Midnite and Limay Media Ltd to ensure their gambling ads do not feature anyone who is, or seems to be, under 25 gambling or playing a significant role.

Midnite’s Earlier Rulings

The decision follows an upheld ruling against Midnite published on August 12, 2026, covering two TV ads, two video-on-demand ads and a radio ad for the betting app. In that case, the ASA found the ads portrayed gambling behaviour that could lead to financial, social or emotional harm and also suggested that gambling was an escape from personal problems.

The ASA’s rulings index lists four further published decisions involving the operator. On June 10, 2026, the regulator did not uphold a complaint about a TikTok post on Mia Mon’s account promoting an online betting platform, finding it did not feature someone likely to be of strong appeal to under-18s. Upheld rulings dated November 26, 2025 and September 17, 2025 concerned posts on Midnite’s X page: the first featured a person likely to have strong appeal to under-18s, and the second featured an AI-generated video depicting footballer Trent Alexander-Arnold that the ASA found had strong appeal to under-18s. A ruling dated December 8, 2021 upheld a complaint about a paid-for Facebook ad for a betting service that was banned for encouraging irresponsible gambling behaviour.

The index also records an informally resolved case involving Dribble Media Ltd t/a Midnite, dated March 4, 2026, with one complaint.