EBU Single Rulebook Q&A 6 October 2020 2020_5534 Bill-payment via postal service

Does bill-payment via snail-mail (postal service) fall into the definition of Article 97 1(c) and thus are subject to strong customer authentication (SCA) requirements? Many banks in Member State A permit "bill payment via postal service" where you send in the bills to be paid in a envelope, along with a "cover sheet".