To clarify my question - how do I factor the text fields to accept HTML formatting beyond <p>?
We want to be able to use HTML text with proper header levels and formatting, and have that also appear on the DoR.

The below header will not show on generated DoR.

However, this will.

Using <p><b> does not allow screen readers on the Adaptive Form to scan by headers. We can't even use panels to act as that as they are coded in AEM as <div>, not a header.

We don't really care if the rich text shows as plain text, but basic, accessible HTML tags are not accepted by the Text field in Designer if we try to update the Generic Document of Record.

Currently, to meet our ADA requirements, we need to double-code, showing the section descriptions on the DoR but not the form, and putting in accessible <h2> in the form but knowing they will not show on DoR. Also, any more intricate text coding will also not show, such as list items and other formatting. So in many cases, we are forced to use custom XDP for forms which slows down our development.
Is there a way to factor an AF_TEXT_XFO to include proper HTML markup? Or is this just a giant ADA gap with Document of Record and we have to continue to use workarounds? Please, if you reply with "refactor x" or "do y", provide examples or code - please do not assume knowledge.
Thank you!