This solution satisfies the original use-case defined as "people who don't want form behavior": <search> without the action attribute behaves as <div role=search>, the same as the original proposal.
Breakdown of individual form features:
- Form submission is disabled if the
actionattribute is unspecified. - Autocomplete is not affected (it is already enabled by default for
<input type=search>). - There is no form validation unless the developer explicitly sets it up.
- There is no reset button unless the developer adds one.
<search>is registered indocument.forms, this has no effect unless the developer iteratesforms, in which case this is expected.- Form controls within
<search>are associated to it. This has no unwanted effect. In fact, it is a reasonable expectation to wire up the form controls within asearchelement since<search>"contains a set of form controls [...] related to performing a search".
The above features are available to the developer optionally, if needed. The original proposal lacks these features and developers have to work around with a nesting pattern that contradicts the common sense expectation, leading to a steeper learning curve, errors and a different a11y tree, that brings up long-dormant bugs.
With these considerations it is unreasonable to restrict the <search> element to <div> semantics and exclude probably the most common usage. Doing so would have negative effects in the long term.