That's not entirely true. I nailed a bandit with my bow, which took two arrows, but I had already drawn the third just in case. After he went down I didn't know how to put that arrow back in mu quiver (I still don't btw) so I walked over to him and put it next to the other two in his chest. That increased my Marksman skill, even though this dude had been dead for over 30 secs. So unless dead bodies count as living targets, there must be something else to it.
And apparently spamming spells at random with no target or real use increases your skill too, so not all skills have to be used effectively.
Its a bit of a glitch I am afraid, you only gain skill poists
after you stop an action or series of actions within combat,
so as long as you keep swinging or holding the arrow knocked your skill will not likely increase..
If you get knocked back, or release a bow and wait a split second it allows the game to catch up with your actions and record your skill points.
This is why in combat at low levels when fight without pausing on the highest difficulty your level 5 combat skills will spam up a couple of points in my experience, rather than moving up by one while I swing away.
Edit: DOOOOOH got ninja'd!!, and more elegantly put too, note to self read everything posted first.