My naive initial assumption (just due to my own bias) was that nesting would work the same way as in Markdown – i.e., that the number of `#`’s indicates the heading level.
Maybe worth for you to consider? It’s a well known convention, it should be fairly self-explanatory, and it would work independent of the notion of paragraphs.
# animals
elephant
## felines
cats
# plants
apple tree
## flowers
lily