Apple Pay does not force the above, as you have already identified yourself via mandatory biometrics or device PIN.
Basically it references the purchase to your history and if there's something funky it forces you to re-auth.
Mostly happens to me on vacations and road trips when I pay in multiple locations 100s of km away from each other.
But I've never had to do it at my local grocery store(s), even though I might visit them multiple times a week.
"In a ‘card present’ scenario, the convenience of contactless at point-of-sale would remain, however customers will be asked to complete a Chip and PIN transaction when they reach the maximum total contactless spend, or have exceeded the card issuer's limits for consecutive contactless transactions since they were last authenticated." [1]
"When you spend around £100 in shops (across multiple payments, not just in one go) without having used Chip & PIN , we’ll do an extra security check by declining the next contactless payment and asking you to use Chip & PIN instead. " [2]
[1] https://www.barclaycard.co.uk/business/business-matters/frau... [2] https://monzo.com/blog/2019/09/11/strong-customer-authentica...
It is pretty annoying because there are a lot of terminals that don't have the PIN keyboard, e.g. on vending machines. If you card decides it needs PIN, you are not buying, unless you can sidestep it using a phone.
It doesn't seem to be universal though. I paid for multiple hotels in Europe (so hundreds of pounds/Euros) with contactless payments and--although I actually made a point of making sure my card had a PIN after a problem on my previous trip--I never needed it.