Mass Effect 2 had a great difficulty system where enemies got smarter the higher the setting, and while it did increase their health/damage it also made dealing with their armor and shields something you had to build your squad around. They were way too spongy in 1 and 3, but 2 hit a sweet spot. Divinity Original Sin 2 also handled difficulty well, and on higher difficulties the encounters felt like puzzles to solve where other tactical RPGs might feel like a slog of the same exact moves after a while.
Mass Effect has the advantage of being more structured in the order you'll enter encounters while being entirely combat-oriented in leveling and squad-based. In Skyrim you don't have any of those advantages: you can enter nearly any dungeon at any time, you can invest perks in non-combat skills making character level comparisons unreliable (a level 20 character with perks in only speech and lockpicking is, in the game's view, as equally suited for combat encounters as a level 20 character with perks in two handed, heavy armor, and archery), and vanilla companions can't effectively shore up the player's weaknesses and can't do even 10% of the things the player can. The devs settled on making most content clearable by lower levels, and since NPC combat AI is extremely simplistic and encounters aren't dynamic (the game will never add/remove enemies with difficulty changes or in response to player performance, or give them better gear/abilities, for example) the only knobs they can really turn are enemy health and damage. Elden Ring, on the other hand, takes the opposite approach in using a fixed difficulty and trusting the player to figure out what they can and can't do, but still manages to be extremely poorly tuned in the late game to where the player feels forced to engage in cheese and use the same broken builds as everyone else. Dragon's Dogma on hard difficulty weirdly made the game easier: enemies did double damage which was only really an issue in the beginning, but they also dropped a shitload more gold so you ended up with much better gear earlier on.
Better difficulty could take a lot of forms, from making encounters more dynamic in the ways listed above to making enemies smarter, in addition to giving them resistances and weaknesses. In any case, it should require the player to learn and engage with the game's mechanics and reward them for playing well and taking on challenges. For the latter I'm a fan of Fallout 4's legendary enem
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