At the moment in the latest Xperience 13 Refresh 1 release there isn't still anything to support this scenario. And you are right, a custom form dummy control with only label needs to be developed. However, on the Refresh 2 which will be released very soon there is a feature for properties support on form sections. By doing so you should be able to implement it as a Title property on your form section. So if you can wait a little bit until it's released - I'd recommend it.