The other unique bit about the US is we have uniquely strong consumer protection laws and a uniquely large amount of fraud.
This has nothing to do with instant payment. Lets say $1000 is lost from your checking account due to fraud then is it covered by visa or mastercard? consumer protection there is different.
With SEPA or UPI it is irreversible but it is the same like you ACH transfer. If you do a mistake then it is irreversible.
Some people here talk about Amex, VISA or mastercard giving free damage insurance on purchase of consumer items like phone etc. That is not consumer protection. That is more like one gets this free insurance for paying yearly fees or maintaining account.
Another reason for fraud is the use of magnetic stripe based card readers.