The US Department of Labor (DOL) often misses its target dates, so another delay would not be unusual. Conversely, there is nothing stopping the agency from issuing new rules before May, either.
Although there remains a chance the Fast Food Accountability and Standards Recovery Act (FAST Recovery Act) could take effect at a later date, it now faces an uphill battle.
Updated to reflect the repeal of the Massachusetts overtime requirement for certain retail employees on a Sunday or on certain holidays, effective January 1, 2023.