Habitable-zone planets in orbit of red dwarf stars may adapt to heavy radiation from stellar flares by forming extensive ozone layers. The radiation itself would cause the necessary ionization of atmospheric oxygen.

This may also help protect any atmosphere present from gradual erosion by stellar flares, and allow a suitable environment for life to develop. A moderated level of radiation from stellar flares may stimulate the evolution of life, via a relatively high rate of genetic mutation, rather than making it impossible.

The article, linked below, also mentions that stellar flares in red dwarf stars typically erupt from near the stars' poles of rotation, This should further protect planets, likely to exist in the rotational plane of the stars, and any life that may exist on these planets.

https://skyandtelescope.org/astronomy-news/shields-up-red-dwarf-worlds-might-adapt-to-hostile-systems/

Here's what I'm wondering wrt red dwarf solar flare activity; and it's one that might not be so easy to answer at present. How much of the increased activity is because it's a red dwarf, and how much is because it's relatively early on in it's life span? My reason for considering this is two fold. First, wasn't our son a bit more prone to certain activity in it's first 500 million or 1 billion years, vs how old it is today? At closer to 5 billion years. it's closer to it's mid-life... On the other hand, red dwarfs have lives considerably longer than 10 billion years, which would place these red dwarves closer to their infancies. Basically, will they quite down somewhat as they approach a point in their main sequence, closer to where our sun is? Problem in answering that one right now however, is given the universes current age, the red dwarfs have a very long time to go, to have actually aged percentage wise, relative to how far along our sun has gotten....

BTW,

https://www.space.com/massive-stellar-flares-exoplanets-study

case in point, which is what has me questioning just how much of the difference wrt solar flares in red dwarfs is age related vs. type star related....

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Yes, red dwarf stars are expected to 'settle down' and stop extreme flaring as they age. Everything about red dwarfs runs in comparative slow-motion, based on their low rate of nuclear fusion.

The problem for potentially habitable planets of red dwarfs is this: Their stars may remain in their youthful, high-flaring stage so long, that they could destroy incipient life with hard radiation, and erode away the planets' atmospheres.

Unless there is a very strong and protective planetary magnetic field, a super-ozone layer, or if high energy flares are, as new research suggests, consistently from near the poles of red dwarfs, this may be the outcome.

Could a planet evolve a new atmosphere, and life flourish, once the red dwarf grows quiescent? Conceivably, especially if early life retreated underground, then reemerged, once it was see to do so.