I've discussed this before, but now I'll approach it from another angle:
i) In Gen 1, the creation of angels is conspicuous by its absence. That despite the fact that angels figure prominently in Genesis.
ii) Then there's the identity of the Tempter in Gen 3. According to the NT, that's Satan.
iii) This in turn raises the question, not only of when the angels were made, but when they fell. If the creation of angels is implicitly included in Gen 1, and you have the Tempter on the scene in Gen 3, that's a rather brief interval between the Lucifer's creation and Lucifer's fall.
Admittedly, Gen 3 doesn't indicate how long after the creation of Adam and Eve this took place. Was it days, weeks, or years?
I'd add that this is more of a problem for YEC than OEC.
iv) A liberal would say this chronological tension is due to two conflicting traditions: the serpentine Tempter in Gen 3 reflects a different tradition than the Satanic Tempter in the NT–which reinterprets Gen 3.
But even if we granted liberal assumptions (which I don't), that proposal lacks explanatory value. It simply relabels the same issue.
For you still have the issue of how evil entered creation so early. Even if you claim the primordial Tempter wasn't Satan, it still functions as an evil agent. The archetypal villain, who resorts to solicitation. Enticement to commit mutiny against their Creator.
v) Indeed, I think the very fact that so little is said about the Tempter is an indication that his reputation precedes him. Not from the standpoint of Adam and Eve, but the reader's. That's part of the dramatic tension. Although this is the first time he makes his appearance on the stage of Bible history, the record of the event took place long after the fact, so it's more like a flashback. The audience is expected to be more discerning than Adam and Eve, because the audience has the benefit of hindsight.
vi) Now, even if Gen 1 implicitly includes the creation of angels, I don't think that puts an intolerable strain on the narrative chronology–not even from a YEC perspective. As I say, the interval between Gen 1 and Gen 3 could be considerable.
Even so, there's a sense in which the Tempter in Gen 3 seems to be much older than Adam and Eve. Has a degree of experience and worldly knowledge which they lack, because it's been around so much longer than they. That's what gives it a tactical advantage.
vii) One solution is that Gen 1 does not include the creation of angels. Not even by implication.
After all, an obvious explanation for the omission is that it didn't happen. It wasn't recorded because there was nothing to record in that respect. Although that's not the only possible explanation, certainly one plausible reason it wasn't mentioned may be because the angels were not created within that timeframe.
And when you think about it, that wouldn't be surprising. Gen 1 is basically an account of how the physical universe came into being. Physical creatures. Even if Cartesian dualism is true, the emphasis in Gen 1 is on the physical side of things. The incorporeal soul is a refinement that's left to subsequent Biblical revelation.
Although angels have the ability to interface with the physical world, they are not a part of the physical world. That's not their natural realm. That's not where they come from. Not their "country of origin" (as it were).
So it's quite possible that they were created apart from or "before" the creation of the physical universe. They normally exist in an alternate reality.
viii) I put "before" in scare quotes because it isn't clear if it's meaningful to arrange these two different scenarios (assuming if they're different) along the same timeline. It's like theories of an oscillating universe. Is it meaningful to say there was a universe before ours came into being? Is it meaningful to say there will be another universe after ours ceases to be? That presumes a common timeline transcending each universe. But how is that grounded?
A better comparison might be the relationship between the physical world and the dream world. "When" did my dream take place? If I take the physical world as my frame of reference, I could say it happened after I went to bed but before I got out of bed.
But what if I take the dream world as the frame of reference? When did I go to sleep or awaken in relation the dream world?
Both the physical world and the dream world have their internal chronologies. And these are independent of each other. The sequence of events in the dream world can't be intercalated with the sequence of events in the physical world, or vice versa. Can't be synchronized. Can't be arranged on a common timeline. Things happen in a certain order within their respective histories, but because what happened in one realm didn't happen in the other, they don't line up. Since what occurred in one realm did not occur in the other, you can't say what happened in one realm is sooner or later than what happened in the other.
When angels "come" to earth, or "return" to heaven, that could be analogous to how humans pass back and forth between the physical world and the dream world. When we awaken, our mind uses the body to interact with the physical world. When we dream, our mind interacts directly with the dreamscape.
Over the course of a lifetime, we have a history of dreams, although most of them are forgotten. By the same token, angels may have a history in the angelic realm. Ancient history. When they "enter" the physical universe, the way our minds use a brain and body, they bring that experience with them.
ix) This dovetails nicely with Synoptic accounts where demoniacs encounter Jesus. Even though it's the first time that the demoniac met Jesus, the possessive spirits act as if it's hardly the first time they met Jesus. Even though Jesus is empirically human, they sense his deeper identity. There's instant recognition. In part, that seems to be spirit sensing the presence of another spirit.
But it's more than that. There's shared history. They remember the Son. They knew him from before their downfall. He is their Creator.