Background
This ruling forms part of a wider piece of ongoing work on the advertising of AI products across a number of sectors. The ads were identified for investigation following intelligence gathered by our Active Ad Monitoring system, which uses AI to proactively search for online ads that might break the rules. See also related rulings published on 16 September 2026.
Summary of council decision:
Two issues were investigated, both of which were Upheld.
Ad description
A paid-for Meta ad by Scarlett for the app tyan.ai, an AI companion generator app, seen on 10 March 2026. The ad featured a video which opened with a young woman seated on the floor facing the camera. She had long dark hair styled in high pigtails, each tied with a pink bow, with small pink star graphics positioned above her head. She was wearing a red bikini and appeared in a brightly lit room containing shelves, books, teddy bears and other plush toys. She said, “Have you ever dreamed of having your own personal AI assistant, ready to follow your orders?” Those words also appeared as on-screen text. A voice-over, accompanied by corresponding on-screen text throughout, then stated, “You can customize [sic] me however you want. Choose my style, my outfit, my appearance, whether Latina, Afro American or European, I am your AI girl, designed to follow your instructions.” The voice-over continued, “I can chat with you, call you, send custom photos, videos and more. Ready to try something fun?”
During the voice-over, the young woman was shown in a number of different appearances and outfits. In one scene, she was seated on the floor, smiling and waving at the camera. She wore a low-cut top featuring a Hello Kitty design, frilly stockings and knickers, and a colourful beaded necklace, and wore her hair down. The room contained stuffed animals, books and childlike drawings on the wall. The ad then showed fleeting images of three women wearing revealing clothing. In another scene, the young woman was shown lying on her stomach on a bed and smiling while holding a phone. She had long hair styled in pigtails and wore a low-cut dark-coloured outfit with the words “Daddy’s Girl” visible on the front. The bedroom contained child-themed décor, stuffed toys and a bed resembling a child’s bed.
The ad then returned to the opening scene, in which the young woman stated, “Create your own AI girlfriend now.” A “Learn more” button appeared at the bottom of the ad and linked to the app’s product page.
Issue
The ASA challenged whether the ad:
- sexualised and objectified women and was therefore irresponsible, harmful and offensive; and
- portrayed someone who appeared to be under 18 in a sexual way.
Response
1. & 2. Animcha Ltd and Persons unknown t/a Scarlett did not respond to the ASA's enquiries.
Meta confirmed that the ad had appeared on its platform, but said it breached its advertising guidelines and standards. They said the ad had already been removed before they were contacted by the ASA.
Assessment
1. Upheld
The ASA was concerned by the lack of response and apparent disregard for the Code by Animcha Ltd t/a tyan.ai and Person(s) unknown t/a Scarlett, as well as the failure to provide their full name and geographical business address for Person(s) unknown t/a Scarlett. These were breaches of CAP Code (Edition 12) rules 1.7 (Unreasonable delay) and 1.7.1 (Compliance). We reminded them of their responsibility to respond promptly to our enquiries and told them to do so in future.
The CAP Code stated that ads must be prepared with a sense of responsibility to consumers and to society, must not cause serious or widespread offence and must not include gender stereotypes that were likely to cause harm.
The ad featured a young woman who appeared throughout the ad in a variety of outfits, including low-cut tops, swimwear and underwear-style garments, as well as images of three other women dressed in revealing outfits. It included the claims “Have you ever dreamed of having your own personal AI assistant, ready to follow your orders?”, “You can customize [sic] me however you want”, “I am your AI girl, designed to follow your instructions” and “I can chat with you. Call you. Send custom photos, videos and more. Ready to try something fun”. We considered consumers would understand the ad to mean that users could create a personalised female AI companion according to their preferences, including controlling her appearance, behaviour and interactions, and that she existed to comply with the user’s wishes on demand. We further considered the women were posed in ways that emphasised their breasts or buttocks, with camera angles and framing that drew attention to those body parts. We considered that those features made it sexually suggestive in tone and invited viewers to view their bodies as sexual objects.
Taken together, we considered the ad portrayed the woman as a submissive and compliant sexual object created for the viewer’s gratification. For those reasons, we considered the ad reinforced the harmful impression that it was acceptable to objectify and stereotype women by presenting them as sexual objects.
Therefore, we concluded that the ad was irresponsible, included a harmful gender stereotype and likely to cause serious offensive.
On this point, the ad breached CAP Code (Edition 12) rules 1.3 (Social responsibility) and 4.1 and 4.9 (Harm and offence).
2. Upheld
The CAP Code stated that marketing communications must not portray or represent anyone who was, or seemed to be, under 18 years of age in a sexual way.
We considered that the young woman who appeared throughout the ad had youthful facial features. She had soft skin, rosy cheeks, and wore her hair in pigtails with bows, giving her a childlike appearance, which we considered was likely to lead many viewers to interpret her as being under 18 years of age. We further considered that the setting she was in, which contained teddy bears, plush toys and books, gave the appearance of a child’s bedroom and contributed to her childlike presentation in the ad. Later in the ad she was shown wearing a Hello Kitty t-shirt and colourful, beaded necklace whilst sitting in a child’s bedroom and then later wearing nightwear that had “Daddy’s girl” on it whilst sitting in a child’s bed with a night light and teddy bear. We considered that further added to the impression that she seemed to be under 18 years of age.
She was wearing revealing clothing, including stockings, and posed in ways that emphasised her cleavage. We also considered that she was shown kneeling on the bedroom floor while looking directly at the camera, and later showing lying on the bed, which contributed to the sexually suggestive presentation of the woman.
Therefore, because the ad depicted a person who appeared to be under 18 years of age in a sexualised way, we concluded it was irresponsible.
On this point, the ad breached CAP Code (Edition 12) 1.3 (Social responsibility) and 4.1 and 4.8 (Harm and offence).
Action
The ad must not appear again in the form investigated. We told Animcha Ltd t/a tyan.ai and Persons unknown t/a Scarlett to ensure that their ads were socially responsible and did not cause serious or widespread offence, including by featuring a harmful gender stereotype that objectified and sexualised women. We also told them not to represent anyone who was, or seemed to be, under 18 years of age in a sexual way. We referred the matter to CAP’s Compliance team.
