UK ASA Rules AI-Generated Characters Subject to Gambling Ad Age Limits in Midnite Case
ASA rebuked Midnite for an affiliate’s TikTok ad using an AI character appearing under 25, confirming CAP Code rules 16.3 and 16.3.14 apply equally to generated content. Midnite ended the partnership and faces orders to tighten AI oversight. The ruling extends age restrictions beyond real people.
SCCG Take — Operators must now enforce explicit AI compliance protocols on affiliates or risk repeated ASA sanctions in a tightening UK ad environment.
The UK Advertising Standards Authority has rebuked operator Midnite after an affiliate-created TikTok promotion featured an AI-generated character that appeared under 25. The ASA determined the content breached the CAP Code because the character’s looks and mannerisms suggested someone too young for a significant role in gambling advertising.
The short-lived advert showed the character speaking directly to viewers with the verbatim message: “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.” It was created by Limay Media and ran for only a few hours. Midnite had no direct role in approving the post and responded by ending its relationship with the affiliate.
ASA Applies CAP Rules to Artificial Characters
Limay Media argued the figure was not a real person, yet the ASA concluded this provided no exemption. The regulator found breaches of rules 16.3 and 16.3.14, which bar gambling ads from featuring those who are or appear under 25 in a significant role. It instructed both Midnite‘s registered company, Dribble Media, and the agency to improve oversight of AI-generated material. The ASA stressed that operators and affiliate marketing partners share compliance responsibility, as first reported by Focus Gaming News.
Andrew Mook, Midnite’s head of brand marketing, had earlier promoted AI’s potential after the firm created an internal AI television campaign. Seven months later, the same technology prompted regulatory action. This marks another ASA finding against the operator, following a full campaign ban last month after 125 complaints and an upheld complaint last year over an advert featuring Son Heung-Min. The ASA did rule in Midnite’s favour on a separate campaign with influencer Mia Mon. It also declined to uphold complaints over gambling ads appearing on a Counter-Strike 2 eSports content website.
Oversight Gaps Exposed by AI Tools
The case highlights execution risks when affiliates deploy AI without sufficient guardrails. While Midnite has committed to reminding partners of contractual and CAP Code obligations, the shared-responsibility finding places fresh compliance burdens on operators. Regulators now treat AI outputs under the same standards as traditional content, leaving limited room for ambiguity on age depiction.
Reporting: Focus Gaming News
Generated by SCCG’s automated editorial system from published source reporting. SCCG Management holds editorial responsibility.
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