Apple Pay supports liability shift globally for all the major networks with the following exceptions:
Liability shift applies only to the initial customer-initiated transactions (CITs). It is not available for merchant-initiated transactions (MITs), since the cardholder is not present on-session for biometrics authentication. Consequently, we strongly advise against processing subsequent card-on-file transactions using Apple Pay. We recommend bringing the customer on-session by presenting the Apple Pay payment sheet again following the Apple Pay integration guidelines. This will create a new payment method that qualifies as a CIT, thereby supporting liability shift.