Night of the Doctor wasn't televised and therefore didn't have to adhere to the rules so strictly. But even putting that aside, all they did was mention names. Meaning for someone who is unfamiliar with the audios, they are just names, and they can still understand Night of the Doctor just fine.In The Night of the Doctor, the 8th Doctor mentions several of his Big Finish audio companions. There is nothing compelling anyone to buy a single episode of those stories.
That doesn't matter, since her appearances still aired on BBC, she's still allowed to be used.For that matter, having Sarah Jane show up in 2006, an unequivocally canonical character, would be very hard to get the full picture of without buying expensive DVDs back then.