It’s not clear this is a compliant approach. There is an EBA Q&A that very strongly suggests that you can’t do this. They make it clear that the SCA needs to be tied to a payment initiation, and generally prove the customer is still in possession of the card.
Of course we’ll keep an eye on these sort of implementations to make sure we aren’t over interpreting the law. But right now our focus is on producing the most user friendly and complaint implementation.
I would assume that other banks £135 limits do include an allocation for offline transactions, they’re just not telling you.
For us it doesn’t feel right telling people they have a £135 limit, when it’s practically impossible for them to actually hit that limit.