Why do we always want numbers for stuff like this? Why not ask "why are we putting a check valve here?"
If "here" is a full-flow bypass around a compressor, then leakage impacts system effeciency but doesn't usually have a major impact on system performance so quite a bit of leakage is often acceptable.
If "here" is downstream of a centrifugal pump, then any leakage below the threshold of rotating the pump backwards it probably OK. Your 10% number probably works here (and that is likely where it came from).
If "here" is downstream of a meter run, then leakage below the measurement threshold is OK (a smaller number than the pump case).
If "here" is under a PSV on a vessel that can operate in a vacuum then the acceptable leakage is even less (since people have so little tollerance for air in pressurized systems).
David